PERFORMANCE AUDIT
DEPARTMENT OF TRANSPORTATION
MOTOR VEHICLE DIVISION - REVENUE GROUP
Report to the Arizona Legislature
By the Auditor General
August 1986
86- 7
DOUGLAS R NORTON. CPA
AUDITOR GENERAL
STATE OF ARIZONA
OFF! CE OF THE
AUDITOR GENERAL
August 18, 7086
?+ embers of the Arizona Lec~ islature
The BonoraSle Bruce Babbitt, Gover~ or
Char1 es L. P: i 11 er, Ei rect, or
Departnznt o f TranspertatSon
Triinsmitted herewith i s a report o f the ktrditor Generai, A Perfarnance
Audit cf - the 3epartzent sf Transportation : 40- tor: lehiclt? Division - ? evecw Group. lfiis report is i n rzsponse to The July 25, 1985 reso'lution o f the
Joint Legislative Oversight Coix~ tit ee.
The report addresses audit coueracle, 1/ 46i t 5electicn and a:, idi tor
productivit: l. ', re bound the Revenue Group ;?.~; viSt ectio~ c onducts too fee:!
audits o f ccr? nerci?' l carriers, rssu- 1 t i n ? i'n p9: er- xial Icsz assessrents 2f up ' t:, li1O. C x i7 o z per year, I t. : e S e c - ~ i c r ?~~ Y O~ C P ~ ? ! J ~ C Sf ~ Sr~ ? F ( J ~ ~ E C
acccuats ;- r: clue; t :? ave c~ useilr ? % yP C C S ~: S: ~ ,: t B P X C !~; lc + ea Fro3 suai t , 3rii
7 . t h i s ? ay r= iuuce taxpayer i n c e ~ t i v e tt? rfoor- t l: axes properly. tic? ~ I S C
disc~: sst :; e potcnti=, l i sss o f !? ore t3an $ 7 . -: { 1~ 1 fnvi: i n revenue resill tiR G
from assign!. n~ audi. tcrs to duties other t: x! n luditin?, and we recormend
ways t o vax- izize auditor productil~ ityt hro:! g~ : l, gtomstion.
I4y staff and I xi11 be pleased t o disctiss ar clarify i t m s i n the report.
DougF.& s E. :! orton
Audi tor General
Staff: > ti1 1 i am Thornson
;+ lark Fl emi ng
Ifartha 5. Dorsey
Jerome E. Xi1 ler
Kurt L. Schul t e
2700 NORTH CENTRAL AVE. SlJlTE 700 PHOENIX, ARIZONA 85004 ( 602) 255- 4385
The Office of the Auditor General has conducted a performance audit of the
Arizona Department of Transportation ( ADOT) Motor Vehicle Division's
Revenue Group, in response to a July 26, 1985 resolution of the Joint
Legislative Oversight Committee. This performance audit i s one in a
series of audits on ADOT and was conducted as part of the Sunset Review
set forth in Arizona Revised Statutes ( A. R. S. ) § § a1 - 2351 through 41 - 2379.
The Revenue Group serves as the revenue processing arm of the Motor
Vehicle Division ( MVD) . The Revenue Group handles a1 1 revenues resulting
from A. R. S. Ti t1 e 28 ( transportation code) : approximately $ 424 mil 1 ion
annually. The major duties of the Revenue Group are to: 1) set up and
monitor commercial carrier accounts to ensure compliance w i t h Title 28 and
other requirements; 2 ) receive, process and distribute a1 1 Tit1 e 28 tax
and license revenues; and 3) audit commercial vehicle and distributor tax
accounts to ensure proper tax reporting.
Additional Audit Staff Could
Generate Millions of Dollars in Revenue-
For the Highway User Revenue Fund ( see pages 5 through 12)
The Revenue Group Audit Section does not conduct enough audits of
commercial carriers. Currently the Section audits only about 2 percent of
i t s accounts annually, resulting in potential lost assessments of as much
as $ 10.9 million per year. While audit coverage varies from s t a t e t o
state, Arizona's falls below that of several other states in a t least two
tax types.
Expanded audit coverage would substantial ly increase audit collections and
improve compliance with Arizona tax laws. Increasing the Section's
current coverage t o 3.1 percent woul d produce approximately $ 1.5 mil 1 ion
in additional assessments, and could be accomplished with current staffing
levels by implementing the productivity improvements recommended in
Finding I I I ( page 17). Increasing coverage to the 10 percent 1 eve1 woul d
require 38 additional auditors, b u t could result in an additional $ 10.9
million in assessments. The Audit Section should develop a plan to
increase audit coverage and use the plan to request funding for needed
staff.
Current Audit Selection Procedures
Are Not Effective ( see pages 13 through 18)
The Audit Section's effectiveness i s reduced by poor audit selection
procedures. Currently, audits are selected based on individual , often
arbitrary judgment and are not selected randomly. As a result, the Audit
Section has audited 57 percent of the largest accounts we analyzed at
least once in the past three years. Flany of the largest accounts were
audited repeatedly. The other 43 percent of large accounts and 96 percent
of the remaining accounts we analyzed have not been audited. Because the
Section focuses i t s efforts on a 1 imited number of large accounts, most
other taxpayers have l i t t l e incentive t o report their taxes properly. For
example, one carrier who was reporting a zero monthly tax l i a b i l i t y was
assessed more than $ 37,000 as the resul t of an audit. Such underreporting
could be causing the State to lose substantial tax revenue.
To improve the effectiveness of i t s audit coverage, the Audit Section
needs to develop selection criteria that ensure random coverage of
accounts. Management should also review accounts to determine factors
upon which selection could be based, including account size, to further
maximize revenue recovery.
The Revenue Grow Could Generate
Additional ~ evenue By Increasing The
Productivity Of I t s Audit Section ( see pages 19 thrcugh 27)
The Audit Section could increase revenue recovered through audit
assessments by approximately $ 1.8 mil 1 ion to $ 2.8 mil 1 ion annual ly by
limiting special project assignments and automating auditor duties.
Currently, auditors spend approximately 35 percent of their time on
nonaudit duties. Using auditors for special projects has cost the State
approximately $ 4.3 mill ion in the past three years, because the audi tcrs
were not using their time t o generate audit assessments. MVD should limit
use of audit staff for special projects.
The Audit Section could further increase productivity and generate more
revenue by automating several audit processes. The experience of other
audit organizations shows that the use of personal computers by auditors
can decrease the time needed to complete each audit by 10 t o 30 percent.
This trans1 ates i nto additional audits with an estimated $ 351,000 to
$ 1.3 mill ion in potential audi t assessments. The Leaisl ature should
consider funding the Audit Section's 1987- 88 budget request for eight
microcomputers and software. Eased on MVD's progress in implementing a
computerized audit program, the Legislature should consider funding
additional requests for computers in subsequent years.
The Audit Section Lacks Adeauate Controls
To Ensure Qua1 ity And integrity O f Audit
tdodifications And Taxpayer Bil i ings ( see pages 29 through 33)
The Audit Section does not have adequate controls to ensure accurate,
justifiable audit assessment modifications and bi 11 ings. Documentation to
support audit assessment modifications reviewed by our staff was either
weak or not available, even though the modifications resulted in
reductions of the original assessment amount and ranged from approximately
$ 500 to $ 368,000. Further, MVD audit supervisors did not sign- off on most
of the modifications after the completion of each audit. The Audit
Section also lacks adequate controls over assessment notifications, since
individual auditors have control over both the audit and the taxpayer
billing.
The Audit Section needs t o enforce existing standards and policies
governing assessment modifications and taxpayer notifications to ensure
that a1 1 modifications are adequately documented and reviewed. ADOT's
Internal Audit Secticn shoul d periodically review the PIVE Audit Section's
internal control s over modifications and taxpayer notifications to ensure
that they are adequate and are working as intended.
MVD Could Reduce Growth In The Number Of
Uncollectible Accounts ( see paaes 35 throuah 371
The Revenue Group has difficulty collecting monies owed from commercial
carrier accounts after a1 1 a1 1 owabl e coll ections procedures have been
attempted. In order to prevent an increase in the number of such
outstanding accounts, the Revenue Group could implement various monitoring
procedures. For example, MVD could use a local publication to track
in- State accounts entering bankruptcy proceedings so the State can f i l e as
a creditor before bankruptcy proceedings are final. MVD could also
improve i t s ability to identify out- of- State accounts that may go bankrupt
by monitoring the financial reporting of all carriers in and out of the
State. I t could also use an outside collection agency to track bankrupt
out- of- State carriers.
TABLE OF CONTENTS
Page
INTRODUCTION AND BACKGROUND . . . . . . . . . . . . . . . . . . . . 1
FINDING I: ADDITIONAL AUDIT STAFF COULD GENERATE
MILLIONS OF DOLLARS IN REVENUE FOR
THE HIGHWAY USER REVENUE FUND . . . . . . . . . . . . . . . . .
Low Audit Coverage Could Mean
Sizeable Revenue Loss . . . . . . . . . . . . . . . . . . . . .
Increasing Audit Coverage Would Generate
Substantial Additional Revenue . . . . . . . . . . . . . . . .
Recommendations . . . . . . . . . . . . . . . . . . . . . . . .
FINDING 11: CURRENT AUDIT SELECTIOh1 PROCEDURES ARE NOT EFFECTIVE. . . . . . . . . . . . . . . . . .
Audit Selection C r i t e r i a Are Poor . . . . . . . . . . . . . . .
Unaudited Accounts Are Not Encouraged To Report Correctly. . . . . . . . . . . . . . . . .
Audit Selection Procedures
NeedToBeImproved . . . . . . . . . . . . . . . . . . . . . .
Recommendations . . . . . . . . . . . . . . . . . . . . . . . .
FINDING 111: THE REVENUE GROUP COULD GENERATE
ADDITIONAL REVENUE BY INCREASING THE PRODUCTIVITY OF ITS AUDIT SECTION . . . . . . . . . . . . . . .
Special Projects Reduce
P o t e n t i a l A u d i t Revenue . . . . . . . . . . . . . . . . . . . .
Automation Would Increase P r o d u c t i v i t y
And Produce More Revenue. . . . . . . . . . . . . . . . . . . .
Recommendations . . . . . . . . . . . . . . . . . . . . . . . .
TABLE OF CONTENTS
Page
FINDING IV: THE AUDIT SECTION LACKS ADEQUATE
CONTROLS TO ENSURE THE QUALITY AND INTEGRITY
OF AUDIT MODIFICATIONS AND TAXPAYER BILLINGS. . . . . . . . . . 2 9
Audit Section Needs to Strengthen
Controls Over Modified Assessments. . . . . . . . . . . . . . . 29
Controls Are Needed Over
Taxpayer Notifications. . . . . . . . . . . . . . . . . . . . . 3 1
Recommendations . . . . . . . . . . . . . . . . . . . . . . . . 32
FINDING V: THE MOTOR VEHICLE DIVISION
COULD REDUCE GROMTH IN THE NUMBER
OF UNCOLLECTIBLE ACCOUNTS . . . . . . . . . . . . . . . . . . . 35
MVD Could Minimize the Growth of Uncol lectibl e
Accounts Through Monitoring . . . . . . . . . . . . . . . . . . 35
II4VD Has Difficulty Collecting
Money Owed For Certain Accounts . . . . . . . . . . . . . . . . 3 6
Recommendations . . . . . . . . . . . . . . . . . . . . . . . . 37
OTHER PERTINENT INFORMATION . . . . . . . . . . . . . . . . . . . . 39
MVD Collections U n i t Has Increased
Collection Of Past Due Accounts . . . . . . . . . . . . . . . . 3 9
Abatement Of Uncollectible Accounts . . . . . . . . . . . . . . 4 0
AREAS FOR FURTHER AUDIT WORK. . . . . . . . . . . . . . . . . . . . 4 1
AGENCYRESPONSE . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3
LIST OF TABLES
TABLE 1 - Personnel Assigned t o MVD Revenue
Group As O f March 1986. . . . . . . . . . . . . . . . . . 2
TABLE 2 - Fuel Use Tax Audit Coverage Comparison
July 1, 1983 Through June 30, 1384. . . . . . . . . . . . 7
TABLE 3 - Other Taxes Audit Coverage
Selected States - 1985 Data . . . . . . . . . . . . . . . 8
TABLE 4 - P o t e n t i a l Annual Assessments From Increased Coverage. . . 10
TABLE 5 - Percentage o f Auditor Time Assigned And
Revenue Lost Due To Special Project
Assignments For Fiscal Years
1982- 83 Through 1984- 85 . . . . . . . . . . . . . . . . . 2 0
LIST OF FIGURES
FIGURE 1 - Projected Increases i n Audit Revenue
Through P r o d u c t i v i t y Gains . . . . . . . . . . . . . . .
INTRODUCTION AND BACKGROUND
The Office of the Auditor General has conducted a performance audit of the
Arizona Department of Transportation ( ADOT) Motor Yehicl e Division ' s
Revenue Group in response t o a July 26, 1985, resolution of the Joint
Legislative Oversight Committee. This performance audit i s one in a
series of audits on ADOT, and was conducted as part of the Sunset Review
set forth in Arizona Revised Statutes ( A. R. S. ) $ 541- 2351 through 41- 2379.
The Revenue Group serves primarily as the revenue processing arm o f the
Motor Vehicle Division ( MVD). The Revenue Group monitors and collects a1 7
revenues resul t i ng from A. R. S. Title 28 ( transportation code), averaging
approximately $ 424 million annually over the past tvlo years. Title 28
revenues include gas and other fuel taxes, commercial carrier taxes,
drivers V icense fees, and vehicle 1 icense plate, t i t l e and registration
fees.
Ttie Revenue Group has three major functions carried o u t by i t s three
sections as described below.
o Compliance Control : Responsible for setting up and monitoring
accounts t o ensure that all co~ mercial vehicle operators are in
compl iance with Title 28 requirements, and rules and rea- ul ations
governing registration and taxation. Thi s includes opening
accounts and determining the appropriate registration fees and
tax and bond amounts.
o Receivables Control : Responsible for receiving and processi~ g
all Title 28 tax and fee payments, accounting for, reporting and
distributing these revenues, and collecting delinquent payments.
o Audit: Responsi b1 e for enforcing co~ rnercial vehicl e and
distributor tax laws by auditing accounts t o ensure proper tax
reporting.
The three sections conduct various activities t o ensure commercial carrier
compliance and remittance of monies owed t o the State. For example, the
Compliance Control Section reviews potential new applicants and renewals
t o ensure proper licensure and appropriate bonding levels. This can
include a yearly review of carriers' bonding levels based on the dollar
amount of business to verify i f the bonds are correct. The Receivables
Control Section processes and accounts for all Revenue Group monies. This
section monitors each motor carrier use fuel tax report which i s filed to
ensure that a specified ratio exists between the motor carrier tax and use
fuel tax. If, for any reason, t h i s r a t i o does not exist, i t signals a
potential noncomplier and the report i s forwarded to the Revenue Group
collection unit for follow- up. The Audit Section provides the final
check. An audit i s the most comprehensive and effective of all the
processes performed.
Staffing And Budget - The Revenue Group's budget i s not separate from the
the budget for the Motor Vehicle Division of ADOT. However, staffing
figures for the three sections pl us the Revenue Group's admi ni s t r a t i on are
presented in Tab1 e 1.
TABLE 1
PERSONNEL ASSIGNED TO MVD REVENUE GROUP AS OF JUNE I986
Budgeted Budgeted Temporary/ Seasonal
FTEs Positions Filled Clerical Pool Empl oyees
Compliance Control 39 3 1
Receivabl es
Control 3 7 2 9
Audit 22 ( I 1 19
Administration - 2 - 2
TOTALS
) This figure includes 17 auditors, one manager, tv: o supervisors and
two support staff.
Source: MVD Revenue Group data.
Scooe Of Audit
Our audit of the MVD Revenue Group focused primarily on the effectiveness
and efficiency of the Revenue Group's Audit Section. Ne focused on the
A u d i t Section because the Revenue Group i s i n the process of designing and
implementing an automated system that will affect most operations in the
Compl iance Control and Receivables Central Sections. The audit addressed
the following specific issues.
s Whether current audit coverage i s sufficient;
e The effectiveness of current audit selection procedures;
Ways t o maximize auditor productivity;
o The adequacy of audi t modi f icati on documentation and supervisory
review, and of certain procedures governing taxpayer billings;
and
s Whether MVD can reduce the growth in the number of uncollectible
accounts.
The report section titled Other Pertinent Information addresses the
productivity of the Revenue Group's collection activities and problems
concerning the abatement of uncol lectibl e 1 iabil i ties.
The Auditcr General and staff express appreciation to the Director of the
Department of Transportation and his s t a f f , and specifically to i4VD's
Revenue Group, for their cooperation and assistance during the course of
tne audit.
ADDITIONAL AUDIT STAFF COULD GENERATE MILLIONS OF DCLLARS IN REVEF! UE FOR
THE HIGHWAY USER REVENUE FUND
The Revenue Group Audit Section does not conduct enough audits of
commercial carriers. Currently the A u d i t Section audits only about
two percent of i t s accounts annually, resulting i n a backlog of
approximately 3,100 unaudited accounts per year. Whil e audit coverage
varies among s t a t e s and among different types of taxes, Arizona's coverage
of a t l e a s t two tax types i s less than the average of other states.
Assigning nore audit s t a f f t o commercial c a r r i e r audits would increase
audit coverage and could resul t i n up to $ 10.9 million per year i n
additional audit assessments.
The Audit Section i s charged w i t h auditing accounts for several different
taxes paid by commercial motor c a r r i e r s , fuel vendors and distributors.*
Taxpayers may be required by law to pay several types of commercial
vehicle taxes. All taxes paid are deposited i n the Highway User Revenue
Fund. A taxpayer's account may consist of more than one tax type. Each
tax type on a taxpayer's account i s referred to as an account type. As of
June 1986, 22,000 taxpayers paid taxes in more than 39,000 account types.
Also as of June 1986, the A u d i t Section employed 17 full- time auditors.
Low Audit Coverage Could
Nean Sizable Revenue Loss
The level of audit coverage achieved by the Audit Section appears to be
inadequate. The Section audits only a small portion of i t s accounts each
* The Audit Section i s responsible for ten different tax and revenue
types: 1 ) use fuel user, 2 ) use fuel vendor, 3) use fuel restricted
vendor, 4) weight distance, 5) gross receipts, 6 ) motor vehicle fuel
distributor, 7 ) motor vehicl e fuel r e s t r i c t e d d i s t r i b u t o r , 8)
international fuel tax agreement, 9) international registration pl an,
10) prorate. According to an MVD supervisor, two types - use fuel
user and weight/ distance ( motor c a r r i e r ) - accol; nt for 82 percent of
the accounts and 52 percent of the assessments.
year and has a substantial backlog of unaudited accounts. Arizona's
percentage of accounts audited is low compared w i t h other states.
Low audit coverage - The Audit Section audits only about 2 percent of the
total number of account types each year. The Section has completed an
average of only 802 audits of account types per year over the l a s t three
years, while the total tax load continues to grow and is now more than
39,000 account types. The 802 audits t r a n s l a t e i n t o approximately 500
taxpayer accounts audited per year out of a total population of 22,000
taxpayers.
The low audit coverage means that the Motor Vehicle Division ( FWD) may be
losing potential revenues because so few accounts are audited each year.
More than 14,000 taxpayer accounts have not been audited w i t h i n the l a s t
30 months, which t r a n s l a t e s i n t o more than 24,700" separate audits of
account types. Based on our suggestions regarding a more appropriate
level of audit coverage, FIVD's backlog coul d be as much as 3,100 accounts
per year. This results i n a loss of up to $ 10.9 million annually i n
potenti a1 assessments ( see page 10).
The backlog also means that many otherwise collectible funds niust go
uncollected, because taxpayers are required in most cases to maintain
records for only three years. Thus, failure to audit i n three years
results in potential revenue that may never be collected.
Coverage i s higher in other s t a t e s - ! dhile audit coverage varies from
s t a t e t o s t a t e and among the various tax types, Arizona's performance
f a l l s below that of several other s t a t e s ' actual performance for two major
Arizona tax types.
j; Although I4VD currently has more than 39,000 account types, the 24,700
unaudited in the l a s t 30 months include only accounts that are over 30
months old and have not been scheduled for audit. The remainina
14,300 accounts incl ude accounts establ i shed wi thi n the previous 3G
months, the approximately 2,400 accounts audited during the past 30
months, and accounts scheduled for audit that have not yet keen
audited.
A t least 13 other s t a t e s are auditing a greater percentage of fuel usage
tax account types. Table 2 shows Arizona i n comparison to the six highest
states and the 35 state average. A t l e a s t four states audit a
significantly greater percentage of weight or mileage account types, as
shown in Table 3, page 6.
TABLE 2
FUEL USE TAX AUDIT COVERAGE COMPARISON
JULY 1 , 1 983 THROUGH JUNE 30, 1 984
Carriers Registered Fie1 d
Rank s t a t e ( 1) For Fuel Use Tax Audits Percentaae
1 Mary1 and 33,116 3,180 9.6
2 Kentucky 29,240 1,808 6.2
3 S. Dakota 9,624 480 4.9
4 Texas 20,100 7 54 3.8
5 Washington 13,588 461 3.4
6 I orva 24,700 81 2 3.3
Arizona
Average for 35 States Surveyed 1.9
Colorado was eliminated from the ranking because of its manner of
counting audits. Audits covering more than one year are mu1 t i p l e
counted.
( 2 ) This number was obtained from MVD and not the bIGA study, since b1VD
had originally supplied incorrect data to the MGA.
( 3) Maine also had 1.3 percent coverage.
Source: Compiled by Auditor General s t a f f from " State A u d i t and
Enforcement Practices ," Report !! o. 9 of the National Governors '
Association Project on Uniform State Procedures for Interstate
Motor Carrier Taxation and Regul ation.
TABLE 3
OTHER TAXES AUDIT COVERAGE FOR SELECTED STATES
JULY 1, 1983 THROUGH JUNE 30, 1984
Carriers Registered Fie1 d
State For Other Taxes Audits Percentage
Oregon
Nevada
Kentucky
Idaho
Arizona
Average for 11 states surveyed 4.1
Other taxes are imposed based on weight and mileage, gross receipts
and mileage, mileage alone, or the number of axles on the vehicle.
Source: Compiled by Auditor General staff from " State Audit and
Enforcement Practices," Report No. 9 of the National Governors'
Association Project on Uniform State Procedures for Interstate
Motor Carrier Taxation and Regulation.
According to Tab1 e 2, the state of Maryland's fuel use audit coverage i s
more than seven times as high as Arizona's. Kentucky's coverage i s almost
five times as high, and a t least 12 other states exceed Arizona's use fuel
tax audit coverage rate. Table 3 shows more rate variances, with Oregon's
weight or mileage tax audit coverage more than seven times and Nevada's
more than six times higher than Arizona's.
Althougl- r there is no recognized standard that specifies an adequate level
of audit coverage, MVD has not established i t s own goals for both coverage
level and revenue recovery. For these reasons, the Audit Section needs to
establish an audit plan that sets coverage and recovery goals. For
example, the Section may want t o consider the 10 percent level suggested
by a National Governor's Association ( NGA) study for home- based interstate
accounts in the International Registration Plan ( IRP). A1 though this
level i s intended only for IRP accounts, Arizona's low overall coverage
combined With the potential high dollar amounts that could be recovered
may make 10 percent a worthwhile goal t o attain.
Increasing Audit Coverage Would Generate
Substanti a1 Additional Revenue
Increasing the Audit Section's coverage ~;! oudl substantially increase audit
collections. However, the Audit Section needs to develop a plan for
increased coverage before any staff are added.
Additional collections - If the Audit Section were to increase i t s current
audit coverage, it could recover substantial additional revenue. The
Section could increase i t s coverage t o 3.1 percent without adding staff.
Increasing beyond 3.1 percent would require additional staff b u t would be
cost effective.
Improving Audit Section productivity could increase audit coverage without
additional personnel . According to ADOT productivity figures, each
auditor has 1,598 hours of avai 1 able time each year. * However, this 1 eve1
i s seldom attained because auditors are frequently assigned to special
projects. The special projects take away from direct audit time and audit
coverage suffers as a result. El iminating special project assignments and
automating several auditor functions ( see Finding I 11, page 17) cculd
increase coverage t o 3.1 percent without adding staff, as shown in Table 4
( page 10).
Audit staff are cost effective because each auditor produces more revenue
than i s expended on salary and related expenses. A t maximum productivity,
the average Audit Section auditor could produce more than $ 249,000 in
audi t assessments per year. ** The average audi tor ' s sa1 ary and re1 ated
expenses are $ 28,429. Thus, each additional auditor could result in a net
* There are 1,776 direct hours available, b u t FIVD excluded travel tine
when calculating assessments per hour. Our analysis indicates t h a t
travel time i s approximately 10 percent. Thus, we used 1,59E hours to
calculate potential audit assessments.
** Annual assessments are based on the average o f $ 3,408 per audit. This
figure is based on current figures of $ 142/ hour times 24/ hour audit =
$ 3,408. New figures based on improved productivity are $ 3,408 divided
by ( 24 times 0.9) = $ 156/ hour. The 90 percent figure i s used because
i t takes only 90 percent as long t o do an audit with automation. The
dollars per hour increase as hours per audit decrease.
increase of more than $ 220,000 i n potential assessments. Even a t the
A u d i t Section's current average level of 60 percent d i r e c t a u d i t time, an
additional auditor would produce a net increase of $ 132,000 i n assessments.
Expanding MVD's audit s t a f f is, therefore, a cost effective means of
producing revenue for Arizona's transportation programs. Tab1 e 4 a1 so
shows several p o s s i b i l i t i e s f o r increased staff and audit assessments.
TABLE 4
POTENTIAL ANNUAL ASSESSMENTS FROM INCREASED COVERAGE
I
Number of Amount of
Auditors Coveraae Assessments Increase
Present 17 2.0% $ 2,733,216
Proposed ( 2 ) 17 3.1 4,208,880 $ 1,475,664
28 5.0 6,965,952 4,232,736
55 10.0 13,683,120 10,949,904
) This is the current level of staffing as of June 1986.
( 2 ) These a1 ternatives assume 1,598 hours of direct audit time and a 10
percent increase in productivity through automation. ( See Finding
111, pages 19 through 27 for an explanation of possible increases i n
A u d i t Section efficiency. )
Source: Compiled by Auditor General s t a f f from A u d i t Section data and
National Governor's Association data.
Our estimates of potential additional revenue recovery are based on the
assumption that the A u d i t Section would generate the same average revenue
per audit hour as i n the past three years even as the number of audits
increased. Authorities note that i f audit selection systems are working
effectively, dollars generated per audit will decline as tax base audit
coverage increases. Thi s occurs because the 1 argest and most productive
accounts are audited f i t- st, 1 eaving 1 ess productive accounts for
subsequent selection. However, as noted in Finding I1 ( page 11), the
Audit Section i s not currently selecting the most productive accounts for
audit. T h u s , improvement i n audit selection may offset any expected
declines i n average collections per audit, a t l e a s t during the f i r s t few
years. The eventual lower assessments ivould s t i l l result i n a revenue
gain because more taxpayers would pay their true 1 iabil ity.
Audit plan needed - The Audit Section needs t o develop a plan for
increasing audit coverage. The plan should focus on the best means for
reducing the backlog through increased productivity and additional staff.
Any kind of expanded coverage beyond that gained through enforcing
100 percent direct audit time for all auditors and automating audit tasks
would require more audit s t a f f , and these staff need to be carefully
phased into the operation. Audit Section management feel that they could
hand1 e up to 20 new staff a t a time as long as there was one supervisor
for every five to seven auditors. However, given the current state of
change within the Section, this may not be possible. Eight to ten new
auditors a year for several years i s perhaps a more appropriate estimate.
MVD i s receiving more auditors, b u t on a limited basis.
ADOT has requesxed some additional auditor positions. The t4VD Revenue
Group submitted a request for 18 auditors in the fiscal year 1986- 87
budget. Five of these positions were submitted by ADOT for legislative
approval. All five positions were funded. ADOT's five year strategic
budget plan has a request for three additional auditors i n fiscal year
1988- 69. ADOT i s also planning to contract some audits. The 1886- 87
budget includes $ 39,000 to fund a pilot project that would involve
contracting with a public accounting firm in Los Angeles. The accounting
firm would perform revenue audits of Arizona tax accounts domiciled in Los
Angeles and the surrounding area.
The level of audit coverage achieved by the Audit Section i s low. This
low coverage could bz costing the State millions of dollars in lost
revenue, and does n o t ensure ccmpliance by the carriers. The Audit
Section needs to develop goals for increasing coverage an@ compliance, and
out1 ine a plan for staff and resources necessary for attaining these goal s.
1 . The Audit Section needs t o develop a plan to increase audit coverage.
Specific objectives should be developed to establish the level of
coverage and the number of audits that need t o be done to meet these
goals. This plan should outline the additional staff and resources
needed, how they are to be phased into this increased effort, and the
time table for implementation. An estimate should be made of the
anticipated additional revenue the effort will bring.
2. ADOT should use this p1a. n in formulating i t s budget and request
funding for the auditor positions to carry out the plan.
3. The Legislature should consider funding additional auditins positions
for MVD in accordance with the plan developed by the Audit Section.
FINDING I1
CURRENT AUDIT SELECTION PROCEDURES ARE NOT EFFECTIVE
In addition to the problem of low audit coverage described in Finding I,
poor audit selection further reduces the Audit Section's effectiveness.
The Section has chosen to repeatedly audit a portion of the largest
taxpayers and has ignored most of the remaining taxpayers. This practice
reduces the incentive for many taxpayers to accurately report their taxes
and has resulted in the loss of potential revenue through underreporting.
To improve i t s effectiveness, the Audit Section should develop a more
systematic selection process.
A~ dti Selecticn
Cr1 t e r ~ aA re Poor
Current audit selection criteria 1 imit the Motor Vehicle Division's ( f 4 V D )
ability t o maximize compliance and revenue recovery. These criteria are
hishly judamental , arbitrary and 1 ack randomness. As a resul t, certain
accounts are audited cn a regular basis while other accounts are virtually
i gnored.
Current selection procedures a1 1 ow Audit Section personnel considerable
subjectivity - in selecting accounts for audit. A1 though IiVD's primary soal
i s t o audit larger acccunts, the audit staff a1 so use other criteria which
i ncl ude past audit results, reporting problerns and the account hol der ' s
geographic location. While some of these criteria may have objective
merit, the lack of any formal system or guidelines means that the chance
of being selected for audit varies widely from one account t o another.
This i s due in part t o the fact that individual auditors, in effect,
select many of the accounts t o be audited. A1 t h o ~ i g h the ultimate
authority for deciding which accounts \ rill be audited lies with the audit
manager, he usual ly assigns audit sel ection responsi bi 1 i ty t o an audit
supervisor who in turn assigns i t to a staff auditor.
As a result, the ! IVD Audit Section has emphasized certain large accounts
i n the sel ecticn process. These accounts are audited r e y l arly, primarily
because audit resources are limited and previous audits have resulted i n
large assessments. Overall , 57 percent of the largest* accounts we
analyzed** have been audited a t l e a s t once and, according to A u d i t Section
management, many have been audited repeatedly. The other 43 percent of
large accounts and 96 percent of the remaining accounts we analyzed were
not audited i n a t least the l a s t 30 months.***
Unaudited Accounts Are Not
Encouraged To Report Correctly
The Audit Section's poor selection procedures appear to have resulted i n
underreporting among some taxpayers. Because the Audit Section focuses
its e f f o r t s on a limited number of large accounts, most taxpayers have
l i t t l e incentive to report t h e i r taxes properly. In fact, several
instances have surfaced in which taxpayers were underreporting their
actual 1 iabil i t i e s . Underreporting may cause the State to 1 ose
substantial highway revenue and a1 so results i n inaccurate management
information regarding actual account size.
L i t t l e incentive to r e ~ o r t properly - Through its poor selection
procedures, the Audit Section is, i n effect, providing unaudited account
holders w i t h 1 i t t l e incentive to properly report taxes owed. Some
trucking companies may decide to underreport ( and save money) because they
know the risk of being audited is low. Therefore, the A u d i t Section's
selection policies may actually encourzge taxpayers to underreport.
Analysis of MVD audit results by Auditcr General staff suggests that some
carriers do underreport. We analyzed a random sample of audi tea accounts
by correlating account size and assessment amount for each account in the
* Largest accounts are defined as those with an average monthly
1iabilit. y of more than $ 5,000.
** Our analysis included a l i active acccunts that have a t least one of
the vendor, fuel use, or motor carrier tax types. We therefore
analyzed more than 17,000 accounts, or more than 77 percent of f1VD's
t o t a l active accounts as of 12- 13- 15.
*** The Audit Section's records only cover the past 30 ~ ionths. Thus, we
were unable to determine how often the audited accounts had been
audited or how long unaudited accounts had existed without an audit.
sample.* The results of t h i s correlation clearly show that there i s s
very weak relationship between account size and assessment amount.** In
short, large assessments could result from smaller accounts i n the
population as well as from the larger accounts.*** The reason for t h i s
relationship may be that some smaller accounts are, i n f a c t , small only
because the taxpayer underreports actual tax l i a b i l i t i e s .
Specific instances of underreporting - Although complete data is not
available, several accounts i n the population clearly indicate that
" small" accounts may i n fact be larger than reported to be. The following
are examples of substantial audit assessments resul ting from reportedly
small er accounts.
e One carrier who was reporting a monthly l i a b i l i t y of zero was
assessed more than $ 37,000 as the r e s u l t of an audit.
9 A carrier who reported $ 1,400 i n monthly l i a b i l i t i e s was assessed
$ 1 9,400 during an audit.
a A carrier whose reported ri: onthly l i a b i l i t i e s were just under
$ 2,500 was assessed $ 31,200 a f t e r an audit.
These examples were disccvered by the T. 1VD Revenue Group and clearly
i l l ustrate the potential for underreporti ng. Cur correl ation analysi s
a1 so indicates the possi bi l i ty that sucn underreporti ng i s taking pl ace
because the larger assessnents were found in the smaller accounts.
* The sample consisted of 169 audited accounts of the total cf 759
active audited accounts as of December 13, 1985, that had a t l e a s t one
of the vendor, fuel use or motor carrier tax types. The sample of 169
yielded a 95 percent confidence level w i t h a r e l i a b i l i t y of -+ 3
percent.
** The correlation derived was . I991 a t the .01 level o f significance,
therefore indicating a very weak re1 ationship.
*** The rreak correlation a1 so suggests that those large accounts that have
been audited repeatedly may be improving their tax reporting. The
closer a taxpayer comes to reaching full complia~ ce ( i . e . , accurate
tax reporting), the lower the audit assessment.
Improper reporting means reduced revenue - Underreporting could be causing
the State to lose substantial tax revenue. A1 though i t bias not possible
to precisely estimate the amount of l o s t revenue, our correlation suggests
that unaudited accounts have the potential for sizeable assessments.
In addition, improper reporting reduces the Audit Section's attempts to
maximize revenue recovery. The Section's assumption that 1 arge
1 iabil i t i e s would lead to 1 arge assessments seemed 1 ogical because big
companies do more business and incur larger l i a b i l i t i e s which usually
result in larger assessments. However, such an assumption depends upon
accurate identification of companies with large 1 iabil i ties. Accurate
identification of a1 1 such companies i s unl i kely without proper reporting
of tax l i a b i l i t i e s .
Audit Selection Procedures
heed To 8e Im~ rcved
The Audit Section needs to develop procedures for selecting audits that
wi 1 1 improve taxpayer reporting. These procedures shoul d i ncl ude
oversampling of large accounts that have not been previously audited and
random sampling of small accounts. Once this has been accomplished other
potentially productive accounts should be oversampled. The Tax and
Revenue Group Automated Tracking System ( TARGATS) i s intended to
facilitate many of these improved procedures, b u t an interim system i s
needed.
To improve the effectiveness of the expanded audit coverage recommended i n
Finding I ( page 5 ) , the Audit Section needs t o develop selection criteria
that ensures greater coverage of unaudited large accounts and random
coverage of a1 1 accounts. With improved selection techniques, audits of
large accounts that have not previously been audited are likely t. o produce
large assessments and help ensure future compliance by major taxpayers.
A t the same time, however, the Audit Section needs t o ensure that all
other taxpayers comply with commerci a1 carrier tax 1 aws through proper
reporting of 1 iabil i ties. Random sampl ing of accounts i s particularly
important because of the underreporting identified by previous EflVD audits
of reportedly smaller accounts that were actually larger than expected.
Whil c these procedures are being imp1 emented, management should
concurrently focus on other potentially productive accounts to further
maximize revenue recovery. Managettent may wish to examine accounts based
on secondary criteria t o determine which accounts should be targeted t o
increase the Audit Section's abil ity to ensure proper reporting and
maximize revenue recovery. Possible criteria coul d be those accounts with
a history of reporting problems ( i. e. reporting zero l i a b i l i t y , failure to
report a t a l l , major record keeping errors uncovered on previous audits),
and accounts that are facing bankruptcy. Other factors to consider could
be changes in company personnel ( i. e. new bookkeeper) and statutory
changes.
The Revenue Group's plans t o improve i t s audit selection criteria appear
adequate b u t will not be implemented for approximately one year. The
criteria planned for the TARGATS system appear to take into consideration
both accwate reporting ( random se1 ecti on) and revenue recovery
( oversampl ing of 1 arge and other potential ly productive accounts).
However, the Audit Section does not plan to implement the TARGATS
selection criteria until September 1987. In the meantime, blVD will
continue to 1 ose potential revenue. The Audit Section should, therefore,
implement these criteria before TARGATS i s brought on line.
Audit Section selection procedurgs may not effectively ensure compl iance
with Arizona tax laws. Consequently, the State could be losing revenue
needed for highway construction and mai~ tenance. Improved selection
procedures are needed t o improve compliance and maximize revenue recovery.
RECOI. lf. iEF! DATI ONS
1. The Audit Section should improve audit selection by:
a. Selecting audits randomly from the entire population of
taxpayers. The Section should implement random selection before
TARGATS is brought on line.
b. Once random selection i s achieved, management shoul d eval uate
various characteristics of i t s accounts t o determine which
accounts would likely result in the greatest potential revenue
recovery. Such characteristics may include account size,
reporting problems, organizational changes within the company,
account age, and period of time since the account was l a s t
audited. If account size i s considered, the Audit Section should
identify large accounts that have n o t been audited and designate
a portion of i t s audit resources to ensure that these accounts
are audited in a timely manner.
THE MOTOR VEHICLE DIVISION REVENUE GROUP COULD GENERATE ADDITIONAL REVENUE
BY INCREASING THE PRODUCTIVITY OF ITS AUDIT SECTION
The Motor Vehicle Division ( MVD) Revenue Group Audit Section could
increase audit assessments by approximately $ 1.8 mil lion to $ 2.8 mill ion
annually through improved Audit Section productivity. Reducing the amount
of time auditors currently devote to nonaudit activities would enable MVD
t o increase audit assessments by more than $ 1.4 million annually. Use of
microcomputers for fie1 d audits woul d a1 so improve individual auditor
productivity, and coul d resul t in additional assessments of $ 351,210 to
more than $ 1.3 mil 1 ion annual ly .
Speci a1 Projects Reduce
Potential Audit Revenue
Use of audit staff for special projects limits the audit assessments
generated by the MVD Audit Section. Time spent on nonaudit projects
durirrg the past three fiscal years cost the State more than $ 4.3 million
in lost assessments. EVD could take several steps t o reduce these losses.
The major duty of the Audit Section i s t o ensure proper payment of taxes
and fees incurred by ccrnnercial carriers. Auditors conduct examinations
of taxpayer/ corporate accounts and reccrds. Other activities are
considered special projects. Serving in acting management or supervisory
capacities, special task force assignments, compiling audit production
reports, and performing clerical functions such as preparing mail outs or
purging files are several examples of activities MVD defines as special
projects.
Loss of revenue - The State i s losin9 a great deal of money because
auditors are taken away from direct audit assignments and placed on
special projects. Further, because special projects require experienced
audit staff, the more complex accounts remain unaudited. Special project
assignments have increased over the last three fiscal years.
Special projects cost the State more than $ 4.3 million i n potential
revenue over the past three fiscal years, and have contributed to a
substantial back1 og of unaudited accounts. Since special projects 1 imi t
the time spent on audits, MVD must forgo potential assessments that
auditors would otherwise produce. Tab1 e 5 shows the potential revenue
losses based on the average assessment per hour from fiscal years 1983
through 1985. In addition, over the past three years the Audit Section
completed an average of only 802 audits per year out of a total of
approximately 39,000 account types.*
TABLE 5
PERCENTAGE OF AUDITOR TIME ASSIGNED AND POTENTIAL
REVENUE LOST DUE TO SPECIAL PROJECT ASSIGNMENTS
FOR FISCAL YEARS 1982- 83 THROUGH 1984- 85
Percentage of Average
Fi scal Special Project ,_, Total Audit Assessment Potential
Year Hours 1 1 1 Hours Per Audit Hour Revenue Lost
TCTAL
Annual
Average 10,101
) Figures exclude all project time charged by the acting audit manager.
( 2 ) Special project time increased i n fiscal year 1984- 85 because two
Audit Section s t a f f were assigned full- time to the TARGATS project.
TARGATS i s the Tax and Revenue Group Automated Tracking System which
will a t t e ~ p to address MVD system deficiencies through automation.
Source: Compiled by Auditor General staff from PIVD A u d i t Section data and
the Field Audit Production Report covering fiscal years 1982- 83
through 1984- 85.
* A carrier account consists of different account types ( e. g., fuel use,
motor c a r r i e r , etc. 1. All account types are subject to audit.
Special project assignments a1 so reduce the experience 1 eve1 avai 1 abl e to
the Audit Section. For example, two special projects* outside the Audit
Section are currently using four of the most experienced auditors with 28
combined years of audit experience. This loss of experience to the Audit
Section reduces i t s a b i l i t y t o complete the more complex audits and
eliminates the assessments that would have resulted from those audits.
Special project assignments account for a growing proportion of auditor
time. During the three- year period from fiscal year 1982- 83 through
1984- 85, special project assignments have increased from approximately 31
percent t o 40 percent of all auditor time, for an average of 35 percent,
as shown in Table 5.
Minimize auditor time spent on special projects - Because of the impact of
special project assignments on audit assessments, MVD should limit the use
of audit staff for these assignments. Management or clerical personnel
could be assigned t o most special projects within the Audit Section. When
audit staff must be used for extended assignments outside the Audit
Section, they should be replaced to ensure full audit coverage.
Use of audit staff for many special projects within the Audit Section
appears to be unnecessary and poorly managed. These projects are usually
of short duration and seldom require auditor expertise. Instead, these
projects could be more appropriately assigned t o an audit supervisor, the
audit group manager or t o clerical staff. Examples of special projects
incl ude: development of future audit schedules, pending cl osure account
review,** and proofreading a proposed audit procedures manual. MVD i s
presently reviewing a1 1 project assignments within the Audit Section.
Corrections will be made so future projects 1 not interfere with
regular auditor responsibilities.
* Projects include TARGATS automation and MVD assuming vehicle county
t i t l e and registration responsibilities for several counties. ** Pending closure account review was defined by Audit Section management
as a clerical function.
MVD uses audit staff on long- term special projects because these projects
require specific expertise not otherwise available in the Division.
Examples of 1 ong- term special projects include the following.
Q TARGATS Project - The Revenue Group i s developing an automated
system ( Tax and Revenue Group Automated Tracking System) to
correct systematic deficiencies in the Group's operations. A
task force was created and recommendations were made t o improve
operations. The TARGATS project task force i ncl uded an outside
CPA firm and employees of the Motor Vehicle Division. Also, an
audit manager and an auditor were selected to serve on this
project full- time. The project assignments are for five years.
The auditors were not replaced.
e Other Long- Term Projects - P4VD Revenue Group auditors often
provide professional assistance in other areas. In the past, MVD
has assigned Revenue Group auditors t o provide technical
expertise t o the Office of Audit Analysis and MVD's Pima County
Title and Registration Office. The auditors have also done
1 imi ted foll ow- up for county t i t l e and regi stration takeovers
after ADOT's Office of Audit Analysis identified problems. An
MVC auditor was also assigned, along with other ADOT staff, t o
he1 p resol ve possi bl e probl ems with Highway User Revenue Fund
monies in Pima County. The MVD auditor remained on the Pima
County project approximately a year and one- ha1 f.
MVD does n o t replace auditors assigned t o long- term projects and this
could cause substantial revenue 1 osses. According to the 11VD Assistant
Director, the Department agreed to absorb personnel costs on the TARGATS
project. As a result, when auditors were assigned they were not
replaced. Therefore, b? VD was willing to forgo the potential assessment
revenue in exchange for TARGATS, because the Director f e l t t, hat the
long- term revenue gain from TARGATS would be greater than the potential
revenue lost. However, the assignment of an audit manager and an auditor
to TARGATS for five years reduces potential audit assessments by more than
$ 477,500* annually. Projected over the five- year period, rep1 acing
auditors could pay for almost one- ha1 f of TARGATS' estimated cost.**
In the future, the MVD Director plans to assign management analysis
section personnel to special projects. However, this section i s currently
staffed with mostly clerical personnel and lacks the expertise to meet
many MVD needs. Future budget requests will seek positions for qualified
technical personnel t o staff difficult and complex projects.
Until the Department has an adequate management analysis capability and
for extended projects where audit staff is absolutely necessary, MVD
should replace any audit staff who are reassigned, to maintain adequate
audit coverage. Use of replacement staff would not only maintain the
Audit Section's ability to ensure compl iance and generate audit revenue,
b u t would also provide for skilled staff in the future.
Automation Could Increase Productivity
And Produce More Revenue
The Revenue Group Audit Section cou1 d increase productivity and generate
more revenue by automating audit processess. MVD auditors are spending an
excessive amount of time performing processes that could be completed in
1 ess time by computer. Automation reduces time consuming activity.
Manual processes hamper potenti ill prodirctivi ty - Lack of automation i s
causing MVD auditors t o be less productive, and a backlog of unaudited
accounts continues to grow. Auditors are spending a great deal of tine
repeating manual processes. Auditors expend considerable time examining
and computing all necessary audit information. Records are examined for
validation of reported information using source documents and sufficiency
of bond coverage. A t the conclusion of the examination process,
* Amount based on average audit assessment per hour of $ 149.41 ( fiscal
year 1984- 85 figure) multiplied by the standard available yearly hours
( 3,196) for two auditor positions. Although one of the transferred
positions was a manager, the net result i s two vacant auditor
positions in the Audit Section.
** Estimated cost of TARGATS implementation i s $ 5.5 million.
the auditor must organize the information gathered on various work
sheets. The auditors use this information to compute the tax assessment
and any penal ty and interest charges. A cal cul ator i s the only aid used
to complete any computations and to verify formulas that determine the
final assessment. An auditor places a1 1 the information gathered from
each audit on three separate work sheets. A personal computer would allow
an automated program to compl ete the process more quickly. Standardized
work sheets and formulas could be stored on the computer and would not
need to be recreated for each audit. The computer would recreate the
schedules and perform computations automatically, thus reducing the amount
of time i t takes to audit an account.
The Audit Section's lack of automation results in limited audit coverage.
Completing audits manually reduces the number of accounts that can be
audited. Conducting fewer audits resul t s in fewer assessments and
increases the backlog of unaudited accounts.
Automation reduces time consuming activity - The use of personal computers
would reduce the time necessary to complete an audit. The use of personal
computers in other audit organizations has increased productivity. The
Motor Vehicle Division has plans t o purchase personal computers during
f i scal year 15' 87- 88.
Financial audit entities with duties similar to the KVD Audit Section have
experienced productivity* gains of 10 percent to 30 percent using
microcomputers. For example, Wisconsin's rlVD Audit Section is responsible
for collecting and auditing motor carrier taxes. Since the auditors began
using computers productivity has increased by 20 percent or more. The
auditors use personal computers to collect specified data. Once the data
i s collected the computer disk with the information i s mailed to the
central office. The field auditors do not make the assessment. This
* Productivity i s defined as the number of audits completed during a
given peri od.
procedure is completed by clerical and management staff in the central
off ice. Since ccmputer implementation, the amount of auditor time
required i n the office to compile audit results has been reduced.
Based on Arizona's audit experience f o r f i s c a l years 1983 through 1985,
simil ar productivity gains would yield additional assessments between
$ 322,322 and more than $ 1.2 million for 1982- 83; and between $ 347,612 and
$ 1.3 million for 1984- 85, as shown in Figure 1."
FIGURE 1
Projected Increases In Assessments
THROUGH PRODUCTIVITY GAINS
2
1.9
1 .8
1.6
1983 1984 19' 85
FISCAL YEAR a 10 % 124 20% 30%
SGU~ CSC:~ inp~ lebdy Auditor General staff frcm MVD Audit Section data and
the Field Audit Production Report covering fiscal years 1982- 83
through 1984- 85.
* Based on a projected gains in audits completed, an overall
productivity gain of 10 percent could have generated an average of
$ 351,210; 20 percent could have generated an average of $ 793,500; and
30 percent an average of $ 1,361,272.
The Arizona Banking Department a1 so reports a favorable experience with
automation. Use of personal computers has increased productivity from 10
to 20 percent. However, productivity gains require training and occur
only after a phase- in period.
The Motor Vehicle Division plans to purchase personal microcomputers. The
budget request for fiscal year 1987- 88 includes funds for eight portable
computers with modem capabilities. The eight computers requested are
similar to the ones used by the state of Wisconsin. The estimated cost of
eight computers i s approximately $ 18,500. This estimate does not include
any software. I t would cost the Audit Section approximately $ 53,500 to
provide computers and software for all Audit Section staff.*
CONCLUSION
The use of auditors for special projects should be limited. The State
potentially lost approximately $ 4.3 mill ion over the last three years
because of lost audit hours. Further, manual audit processes cost the
State between $ 351,210 t o more than $ 1.3 million in potential assessments
due to unaudited accounts.
REC OI,: MEI, IDATI ONS
1. MVD should limit use of audit staff for special projects by:
a. using personnel from other sections and ADOT divisions;
b. rep1 acing auditors on extended speci a1 projects with temporary
auditors t o provide continued full audit coverage; and
c. scheduling and managing special projects within the Audit Section
so they do not interfere with regular audit assignments.
* The cost includes 20 computers with modems and LOTLIS software at
$ 2,671. This cost does not incl ude any formal software training. The
price includes computers for 17 auditors and three supervisory staff.
2. The Legi sl ature shoul d consider funding microcomputers and software
for the MVD Audit Section. The Legislature should consider providing
MVD with the funds requested in the fiscal year 1987- 88 budget for the
initial purchase of eight microcomputers. Based on MVD's progress in
utilizing i t s computers, the Legislature should consider funding
additional requests for computers in future years.
3. The Audit Section should develop procedures to i~ plement the use of
personal computers. The procedures should include obtaining correct
software and developing templates and formulas t o assist in
calculations. Auditors should be provided with formal and on- the- job
training so the computers can receive maximum usage and accounts will
continue t o be audited during phase- in.
THE AUDIT SECTION LACKS ADEOUATE CONTROLS TO ENSURE THE OUALITY AND
INTEGRITY OF AUDIT MODIFICATIONS AND TAXPAYER BILLINGS
The Audit Section of the Motor Vehicle Division ( MVD) does n o t have
adequate controls to ensure accurate, justifiable audit assessment
modif ications and bill ings. Technical review and documentation of
assessment modifications i s weak. A1 so, procedures for bi 11 i ng taxpayers
lack sufficient separation of duties.
Audit Section Needs To Strengthen
Controls Over Modified Assessments
Presently, control over assessment modifications made by MVD auditors i s
minimal, a1 though such decisions may involve hundreds of thousands of
dollars. Documentation of auai t assessment modifications was either weak
or not available. Also, evidence of supervisory review was not apparent.
Supervisory review and internal controls are needed t o reduce the risk of
collusion, bribery or other illegal acts.
Audit assessments are additional tax amounts owed to the State by
commercial carriers. Audit assessments can occur after an auditor
conducts an examination of a commercial c a r r i e r ' s records. In addition,
if a taxpayer disagrees with the original assessment, a modification can
be requested. ! 4odifications are changes based on new information
presented or clarifications made by the audi tee. Modified assessments can
increase or reduce a taxpayer Is 1 iabil ity. Audit section procedures call
for approval of all modifications by the auditor's immediate supervisor.
Documentation and review of modified assessments i s 1 imited - The Audit
Section has weak documentation and limited review of modifications. A
review of modified assessments* by Auditor General staff found weak
documentation for the changes made. Modifications ranged from
* A random sample of 169 carrier accounts disclosed 17 cases with
modified assessments. A1 1 assessment modifications resulted in lower
l i a b i l i t y for the carrier.
approximately $ 500 to $ 368,143, and all modifications resul ted i n
reductions of the original assessment amount. Often documentation was
l i t t l e more than a cryptic note. In one case, reasons for a reduction of
almost $ 54,000 consisted of a few words scribbled on scratch paper. In
many cases modifications were based on information that had not been
available a t the time of the original audit assessment, yet even when
records needed to document the nodifications became available, the
auditors did not obtain them. In other instances, supporting
documentation was in the auditor's possession rather than in the audit
f i l e as required by MVD procedures.
MVD audit supervisors had not reviewed most of the modifications in the
sample. Audit Section procedures require supervisory sign- of f a t the
completion of a1 1 audits. A1 though the final audit resul t s were confirmed
by the supervisor, no documentation of supervisor agreement with the
modification was available in many of the files.
Controls and documentation are needed - Controls and documentation are
needed t o reduce the risk of audit personnel abusing their responsibility
and authority. blhile MVD has agreed to implement controls, the Arizona
Department of Transportation ( ADCT) should take steps t o ensure that these
controls are appropriate and in force.
Lack of documentation presents the opportunity for auditor abuse. For
exampl e, auditors might compromi se their work by knowingly issuing an
incorrect assessment mcdification i n response to improper influence by the
taxpayer. Because audit modif icaticns often i nvol ve thousands of do1 1 ars,
the risk and opportunity for such abuses are real.
Because documentation of audit assessment changes i s limited, technical or
judgmental errors can also be made. For example, errors can be made in
applying statutes, rules and Department policies. These errors may result
in incorrect assessments, inconsistencies among auditors and unfairness to
taxpayers.
The Audit Section has indicated that i t will act t o enforce existing
pol icy t o reduce possible abuses. For example, all original and amended
audit doclrments will be retained i n the audit master f i l e . Also, any
documents relating t o an assessment will be included in the f i l e . The
audit supervisor and manager will review and approve any modified audit
assessments. In addition, the new audit manual will provide specific
procedures and guide1 i nes to help auditors determine what information will
be considered in order to modify an original assessment.
Although the Audit Section has agreed to make needed improvements, ADOT
internal audit personnel shoul d periodical ly review modification
procedures to ensure their appropriateness. Follow- up by ADOT internal
audit personnel will enable an outside source to review these controls.
A1 so, ADOT's Internal Audit Group can advise the MVD Audit Section on how
to strengthen other existing controls.
Controls Are Needed Over
I axpayer Notifications
The Audit Section should strengthen controls over billings that notify a
taxpayer of the assessment owed. Current Audit Section procedures lack
separation of duties over taxpayer notifications.
Audit Section procedures give an auditor sole responsibility to complete
and send out a billing. A1 though an audit supervisor reviews the audit
f i l e for completeness before the billing i s sent out, the f i l e i s then
given back to the auditor. The auditor has the responsibility to ensure
that the billing i s made out t o the taxpayer, along with a " letter of
audit Finding." A clerk then types the billing b u t does not necessarily
verify if the amount i s correct or accurate. No supervisor reviews the
typed billing before i t i s sent to the taxpayer, nor does anyone compare
payments with the audit assessment in the f i l e . Thus, the auditor has an
opportunity to change the bill i ng without detection.
Current Audit Section procedures lack adequate separation of duties as an
internal control. The principle of separation of duties* requires that an
individual responsible for an audit cannot simul taneously be responsible
for making the assessment and preparing the billing without a third party
sign- off or verification. An auditor who performs an audit should not
have sole responsibility for preparing and mailing the billing without a
check- off system.
With 1 imited final review and inadequate separation of duties, a potential
for auditor abuse exists. The auditor could possibly reduce the amount of
the assessment or never mail the billing due to the lack of third party
verification. The lack of separation of duties increases the chances of
employee error, theft or falsification of records.
CONCLUSION
The Motor Vehicl e Divi sion Audit Section should improve control s over
assessment modifications and taxpayer notifications. Modifications and
billings need to be checked for quality, and controls are needed t o
minimize the risk of abuses. Supervisory review of modified assessments
and taxpayer notifications needs to be strengthened.
RECCrlMEl- JDATI CNS
1. The /: VC Audit Section should require that all auditors comply with
existing standards and policies governing assessment modifications and
taxpayer notifications. All reasons supporting modified assessments
should be documented in audit files.
2. The rfVD Audit Section should require supervisory review and sign- off
of modified assessments.
X- Ihe Codification of Statements on Auditing Standards, an authoritative
guide published by the American Institute of Certified Public
~ ccountants, i ~ cudle s separation of duties as a basic internal control
requirement.
3. The MVD Audit Section should implement procedures t o ensure separation
of duties over a1 1 taxpayer notifications. The procedures shoul d
require sign- off or verification by a third party.
4. ADOT internal audit personnel should periodically review MVD Audit
Section i nternal control s over modi f icati ons and taxpayer
notifications to ensure that they are working as intended. The review
should include testing the adequacy of the controls, and suggestions
for strengthening controls if they are inadequate.
THE MOTOR VEHICLE DIVISION COULD REDUCE GROWTH IN THE FflIFIBEF! OF
UNCOLLECTIBLE ACCOUNTS
The Motor Vehicle Division ( NVD) Revenue Group has difficulty coll ecting
some accounts. MVD could minimize the growth in the number of
uncoll ecti bl e accounts through various monitoring procedures. Once
accounts become uncollectible, the cost of collection i s frequently
prohibitive.
An uncollectible account i s defined by the Revenue Group as an outstanding
liability of a commercial carrier account after all allowable in- house
collections procedures have been attempted.* The Revenue Group estimates
that the current bal ance of uncoll ecti bl e accounts exceeds $ 3 mil 1 ion.
According to Revenue Group c f f i c i a l s , a large proportion of the accounts
represent monies owed by bankrupt commercial carriers.
MVD Coul d Minimize The Growth Of
Ifncci 1 ecti bl e Accounts Throucrh Ihni tori no
The Revenue Group could implement monitori~ g procedures t o reduce the
number of uncollectible accounts in the future. A major factor in the
grorvth of these accounts i s I'jlVD1s i nabil i ty to identify troubled carriers
prior t o bankruptcy. The inability t o determine if a carrier i s in
bankruptcy court means the State cannot be considered a creditor and i s
not allowed t o collect on that l i a b i l i t y once the bankruptcy i s final.
MVD could track i n- State accounts entering bankruptcy proceedings by
monitoring a month1 y pub1 ication, the Arizona Court Reporter, which
detail s Dankr~ lptcy i nfornation about Arizona based businesses. Col 1 ectors
could research the document to ascertain if any of the businesses listed
have outstanding unsecured accounts with MVD. The State would then be
able to establish itself as a creditor before bankruptcy proceedings are
final. The Arizona Department of Revenue uses this report and states i t
is very successful.
x The Revenue Group refers t o uncoll ecti bl e accounts as " unsecured
l i a b i l i t i e s . "
MVD could also improve i t s a b i l i t y t o identify out- of- State accounts that
may go bankrupt. The state of Washington monitors the financial reporting
of all carriers in and out of the state. I f a carrier's tax reports are
more than 60 days late or the carrier does not submit proper payment, the
carrier will be contacted to determine i t s financial status. If problems
continue, the state monitors the account closely to ascertain if
bankruptcy i s pending. If bankruptcy appears likely the agency will
request the Attorney General to f i l e a lien against the carrier so the
state will be able to receive all or a portion of the monies due.
The Revenue Group could also use an outside collection agency to track
bankrupt out- of- State carriers. This agency could track outstanding
accounts nationwide. The state of Oregon uses an outside collection
agency for this purpose and has found i t t o be successful.
Control of uncollectible accounts will also be improved by the
implementation of an automated tracking system. This system will enable
the Revenue Group t o better track and identify outstanding billings before
they become uncoll ectibl e. Presently, MVD i s unable to monitor carrier
accounts on a daily basis. Such monitoring will be possible with the Tax
and Revenue Group Automated Tracking System ( TARGATS) currently being
devel oped.
I4VD Has Difficulty Collecting
Monev Or~ ed For Certain Accounts
The Revenue Group has di fficul ty col 1 ecting uncol 1 ectibl e accounts because
some account balances are too small for collection by the Attorney
General.* HVD can request the Attorney General's Office t o collect on
these accounts, b u t because HVD i s charged an administrative fee and a
percentage of the amount collected, collection by the Attorney General ' s
office i s not cost effective for most accounts. Even some accounts with
larger balances may not be cost effective for collection by the Attorney
General ' s Office. Unsecured accounts with balances of $ 100 or more are
* The Revenue Group can submit accounts with balances of $ 100 or more t o
the Attorney General ' s Office for coll ection. This procedure i s used
a f t e r a l l in- house Revenue Group collection attempts are exhausted.
reviewed by the Attorney General's Office t o determine the likelihood of
collection. After review, if the Attorney General ' s Office decides the
account may not be cost effective t o collect or the carrier i s bankrupt,
the account is not pursued.
The Revenue Group i s considering using a private collection agency to
ensure payment of uncollectible accounts. The state of Oregon has had
success in using an independent agency to coll ect out- of- state accounts.
While the agency would receive a percentage of the amount i t collects as
i t s fee, the State would be receiving a t least some remuneration.
CONCLUSION
The Revenue Group has difficulty collecting accounts identified as
uncollectible. MVD could reduce the growth of these accounts through
several different monitoring procedures. Col 1 ectors coul d use an outside
agency t o ensure payment of uncoll ecti bl e accounts.
RECOMMENDATIONS
1. MVD Revenue Group should attempt to identify uncol lectibl e accounts as
early as possible. This could be achieved through:
a. consistent monitoring of the commercial carriers' financial
condition;
b. using the Arizona Court Reporter t o identify bankrupt carriers,
so the State can establish itself as a creditor in arder to
receive any l i a b i l i t i e s due; and
c. employing an outside collection agency to track and collect
accounts nationwide after a1 1 standard col lection procedures are
exhausted.
OTHER PERTINENT INFORMATION
During the audit we developed pertinent information in the following two
areas: 1 ) the Motor Vehicle Division's ( F4VD) collection of outstanding
1 iabil i t i e s , and 2 ) the abatement of uncol lectable 1 iabili ties due the ! 4VD.
MVD collections unit has increased collection of past due accounts
Due to improved coll ection procedures, MVD revenue coll ection has
increased. FlVD collectors are responsible for tracking and collecting
delinquent amounts due MVD. This includes money from audit assessments,
dishonored checks, and all other outstanding 1 iabil i ties. If a 1 iabil i ty
remains unpaid after a certain period of t i ~ e , collectors have legal
alternatives available t o assist them in collecting the delinquent amount.
The amount of revenue collected has almost doubled since fiscal year
1983- 84. The unit collected over $ 4.9 million in 1984- 85, up from
approximately $ 2.7 million in 1383- 84. As of February 1986 the unit has
already collected over $ 5 mill ion for the 1985- 86 fiscal year.
Auditor General staff found overall coll ector productivity to be crest1 y
improved. We reviewed a sample of delinquent accounts and determined that
either the accounts had been closed, or of those accounts assigned to a
collector some type of payment was currently being received. Improved
productivity is due in part to standards* developed in the Productivity
Resource Flanagement System ( PRMS) Group report. In 1983 the PRPlS Group
determined that certain standards were needed for the unit t o become more
productive. From that PRFiS study, present coll ection practices evolved.
* Standards included better tracking of aged accounts and development of
productivity measures for a1 1 col 1 ection personnel . Personnel are
tracked by the number of accounts closed, the length of time taken t o
close an account and the percentage of the amount owed that was
collected on an account.
Abatement Of Uncoll ectabl e Accounts
Presently, uncoll ectabl e revenue from closed comnercial carrier accounts
and unsecured l i a b i l i t i e s owed to MVD cannot be written off. This i s
because MVD has no specific statutory abatement policy. However, Arizona
constitutional law questions may have to be addressed before such
abatement can occur.
As noted in Finding IV ( see pages 9 through 33) a number of account
balances exist that are uncoll ectabl e for several reasons : Many accounts
have small balances; i t may not cost effective to pursue collection; and
the carrier i s bankrupt or has filed for bankruptcy protection.
Since many of the accounts are uncollectable the Revenue Group is
considering seeking legislation t o give i t clear authority t o abate those
accounts. A1 though A. R. S. $ 41 - 1 92. B. 4 gives authority to any state agency
and the Attorney General's Office to " compromise or settle" a claim owed
the State, this authority may not apply t o trust fund monies. According
to a Tax Division Attorney General representative, because the l i a b i l i t i e s
are specifically earmarked for the highway trust fund and not the general
fund, there i s a question as t o whether ADOT can write off the l i a b i l i t i e s
without specific 1 egislation. Such 1 egislation would be similar to a
statute which allows the Department of Revenue ( D O R ) to write off an
account as a bad debt if the cost t o collect the account exceeds the
amount outstanding.
AREAS FOR FURTHER AUDIT WORK
During the course o f our a u d i t we i d e n t i f i e d two p o t e n t i a l issues t h a t we
could not pursue due t o time constraints.
Are s t a t u t o r y changes needed i n procedures f o r paying taxes on
commercial fuel ~ urchases?
TIie Motor Vehicle Division ( PIVD) has d i f f i c u l ty determining whether
c e r t a i n fuel taxes have been paid. Motor c a r r i e r s may pay taxes a t the
time o f purchase and claim a c r e d i t f o r any overpayment, or they may pay
the tax along with other taxes a t the close o f t h e i r normal r e p o r t i n g
period. When the d e f e r r a l procedure was o r i g i n a l l y establ i shed, c a r r i e r s
had t o obtain MVD approval t o d e f e r t h e taxes. However, the growth i n the
number of c a r r i e r s and vendors made it d i f f i c u l t f o r MVD t o enforce the
d e f e r r a l agreement. Since November 1981 vendors have been allowed t o s e l l
fuel to any c a r r i e r and rEed only note on the invoice whether the tax was
paid or not. However, t h i s does not always occur. The documentation
needed t o monitor the d i f f e r i n g paymerlt procedures i s sometimes lacking.
MVD records i n d i c a t e t h a t some c a r r i e r s pay no tax a t the pump but
actual ly c l aim c r e d i t f o r paying those taxes. These comrnercial c a r r i e r s
may be receiving erroneous t a x c r e d i t s . Further a u d i t work i s needed t o
determine how much revenue i s being l o s t by the State because o f erroneous
c r e d i t s , and t o evaluate the impact and effectiveness o f a l t e r n a t i v e s f o r
col 1 ec ti ng the taxes.
Does MVD adequately track commercial c a r r i e r bonding l e v e l s ?
MVD requires a l l commercial c a r r i e r s to maintain a f i n a n c i a l bond. Trre
bond i s used as insurance against tax l i a b i l i t i e s incurred by the c a r r i e r ,
and provides MVD w i t h some type of payment i n case o f c a r r i e r insolvency
or bankruptcy. However, we found t h a t some bonds are i n s u f f i c i e n t t o
cover p o t e n t i a l 1 i a b i l i t i e s . According t o an I s i V D col l e c t i o r i s o f f i c i a l , of
3,000 bond claims made from A p r i l 1985 through March 1986, 35 percent o f
the c a r r i e r s examined biere undersecured. For example, one c a r r i e r haa d
bond o f only $ 12,000 when it should have been $ 55,000. Moreover, a Revenue
Group official stated that MVD does riot systematically review bonds to
ensure their adequacy. Further audit work is needed to determine the
extent to which MVD tracks commercial carrier bonding levels.
a BRUCE BABBITT
Governor August 14, 1986
CHARLES L MILLER
D, rec: or
Douglas R. Norton
Auditor General
Office of the Auditor General
2700 Korth Central Avenue
Suite 700
Phoenix, Arizona 85004
Dear Plr. Norton:
hy staff and I have reviewed the greliminary Auditor General's
Performance Audit of the Arizona Department of Transportation,
Plotor behicle Division, Revenue Croup. Because of the ongoing
changes within the Revenue Group and the general upgrading of the
P1iotor behicle Divison's revenue collection systems, the Auditor
General's Performance Audit of the Revenue Group has concentrated
on the Revenue Group Audit Section.
After careful review, I am in basic agreement with the findings
and recommendations of the Performance ~ udit Report. Only in
minor areas dealing with inferred supportive data associated with
certain findings do we disagree. These areas are included with
the attached detailed discussion.
The majority of the recommendations are consistent with currently
ongoing management programs to enhance the revenue collection,
accounting and distribution systems within the Fotor Vehicle
Division. A major enhancement program that will have a
tremendous inpact on th- audit function is the Tax and Revenue
Croup Automated Tracking System ( TARGATS) program. TARGATS will
provide for better tracking of carrier mileage, tax assessment
based on that mileage, random selection of accounts to be
audited, and computerized programs to facilitate the actuai
auai t .
The Department has assigned two auait positions to the TAKGATS
pro2ect during the uesiyn ana development stdqes of approximately
three years. The resulting revenue benefit to the state in
enhanced revenue collections are projected at three million
dollars per year. The prolected increased revenue collections
were the basis of the decision to use audit expertise. The
HIGHWAYS AERONAUTICS MOTOR VEHICLE PUBLIC TRANSIT ADMlNlSTRArlVE SERVICES TRANSPORTATION PLANNING a
PAGE 2
Department w i l l r e p l a c e t h e a u d i t o r s a s s i g n e d t o t h e p r o j e c t f o r
t h e d u r a t i o n of t h e p r o j e c t .
I am i n g e n e r a i agreement w i t h F i n d i n g # 3 , " The Motor V e h i c l e
D i v i s i o n Revenue Group Could G e n e r a t e A d d i t i o n a l Revenue By
I n c r e a s i n g t h e P r o d u c t i v i t y of Its A u d i t S e c t i o n . " he a r e i n
agreement t h a t t h e a u d i t s t a f f n o t be u t i l i z e d on s p e c i a l
p r o j e c t s n o t r e l a t e d t o t h e c o l l e c t i o n , a c c o u n t i n g or
d i s t r i b u t i o n of Highway User Revenue Funds. S t e p s a r e being
t a k e n t o a s s u r e t h a t 80%- 90% of t h e a u d i t s t a f f is u t i l i z e d
a u d i t i n g revenue y i e l d i n g a c c o u n t s . However, Department of
ran sport at ion management h a s d e t e r m i n e d t h a t t h e a u d i t s e c t i o n
w i l l conduct non- revenue y i e l d i n g a u d i t s such a s r e s t r i c t e d
d i s t r i b u t o r a c c o u n t s . These a u d i t s a r e a b s o l u t e l y n e c e s s a r y t o
i n s u r e t h a t g a s o l i n e t a x r e v e n u e s a r e p r o p e r l y r e p o r t e d and
d i s t r i b u t e d t o t h e r e s p e c t i v e a c c o u n t s o f t h e s t a t e , c o u n t i e s and
c i t i e s . I t is e s t i m a t e d t h a t a p p r o x i m a t e l y 10% of t h e c u r r e n t
a u d i t s t a f f is r e q u i r e d t o a d d r e s s t h i s a u d i t r e s p o n s i b i l i t y . In
a d d i t i o n , t h e r e a r e many o t h e r r e l a t e d f u n c t i o n s t h a t r e q u i r e
a u d i t 5 x p e r t i s e a t t e n t i o n t o i n s u r e t h e i n t e g r i t y of t h e
D e p a r t m e n t ' s t r u s t e e s h i p of t h e Highway User Revenue Funds.
Attached f o r your r e v i e w a r e s p e c i f i c comments r e l a t i v e t o each
of t h e f i n d i n g s and recommendations p r e s e n t e d i n t h e Performance
Aucl t Kepor t . I want t o thank you and your s t a f f f o r t h e
c o o p e r a t i o n , a s s i s t a n c e and c o n s i d e r a t i o n g i v e n t o our
o b s e r v a t i o n s and comments d u r i n g t h e a u d i t 2 r o c e s s .
i CI- iARLES L. MILLER
D i r e c t o r
Department o f T r a n s p o r t a t i o n
FINDING I
Additional Audit Staff Could Generate Millions of Dollars
i n Revenue for the Highway User Revenue Fund
The Department of Transportation agrees with the proposition that
more auditors w i l l generate more assessments for the Eighway User
Revenue Fund. The Department however, does not agree with the
supporting s t a t i s t i c a l data that would indicate a low audit
coverage implied by Table 2 and Table 3 of t h e r e p o r t , since the
organization of audit sections vary from s t a t e t o s t a t e and the
data was never verified.
The Department agrees with the recommendations and has requested
and been appropriated additional a u d i t p o s i t i o n s . The Motor
VeElicle Eivision has included requests for additional auditors in
the Division's five year operating budget plan. The basis for
the past and current requests is t o allow the audit function t o
grow consistently with the growth i n t o t a l HURF revenues. The
additional amount of assessments the additional auditors w i l l
generate w i l l almost certainly exceed, by significant margin, the
additional a u d i t c o s t s . A more exact estimate of revenue yield
from additional auditors is not possible t o predict and such a
forecast is highly speculative. ?\% ether additional s t a f f w i l l
yield revenues at the same recovery r a t e as existing s t a f f is not
possible t o predict.
FINDING 11
Current Audit Selection Procedures Are Rot Effective
The Department agrees with t h i s finding, however, not with the
supporting data. The report presents instances of underreporting
by small accounts implying that t h i s may be a population trend.
Yet, the report i t s e l f s t a t e s , "... complete data is not
available, ..." If corplete data i s not available inferences
should not be made.
The Department agrees with the intent of the recommendations that
an improved a u d i t selection process i s needed. A s mentioned in
the report, the Revenue Group w i l l improve i t s audit selection
process through the Tax and Revenue Croup Automated Tracking
System ( TARGATS). I n the interim, the Pudit Section is
developing manual selection c r i t e r i a that w i l l p a r a l l e l the
TARGATS process.
PAGP 3
FIMDING I11
The Motor Vehicle Division Revenue Group Could Generate
Additional Revenue By Increasing the Productivity of
Its Audit Section
The Departpent agrees with this finding but with reservation. It
is the opinion of the Department that the function of the MVD
Audit Section include, necessary but limited, activities not
related to direct tax audit assessments.
The Department agrees that audit staff productivity can be
increased through the use of personal computers and has included
a budget issue for FY 87/ 88 requesting them.
FIMDING IV
The Audit Section Lacks Adequate Controls to Ensure The
Quality & Integrity of Audit Modifications & Taxpayer Billings
The Department of Transportation agrees with this finding. The ( I
recommendations are being implemented to insure existing
standards and policies governing assessment notification and
taxpayer notifications are complied with. The Audit Section will
require supervisory review and sign- off of all modified
assessments.
( I
FIWDING V
The Plotor Vehicle Division Could Reduce Growth
In The Number of Uncollectable Accounts
The Department agrees with this finding. The Department agrees
with the recormendations and has established close coordination
with Arizona Attcrney General's Office to identify bankrupt motor
carriers so as to establish the State as a creditor. The Motor
Vehicle Civision will investigate the legality and effectiveness
of an outside collection agency to track and collect accounts
nationwide. ( I

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PERFORMANCE AUDIT
DEPARTMENT OF TRANSPORTATION
MOTOR VEHICLE DIVISION - REVENUE GROUP
Report to the Arizona Legislature
By the Auditor General
August 1986
86- 7
DOUGLAS R NORTON. CPA
AUDITOR GENERAL
STATE OF ARIZONA
OFF! CE OF THE
AUDITOR GENERAL
August 18, 7086
?+ embers of the Arizona Lec~ islature
The BonoraSle Bruce Babbitt, Gover~ or
Char1 es L. P: i 11 er, Ei rect, or
Departnznt o f TranspertatSon
Triinsmitted herewith i s a report o f the ktrditor Generai, A Perfarnance
Audit cf - the 3epartzent sf Transportation : 40- tor: lehiclt? Division - ? evecw Group. lfiis report is i n rzsponse to The July 25, 1985 reso'lution o f the
Joint Legislative Oversight Coix~ tit ee.
The report addresses audit coueracle, 1/ 46i t 5electicn and a:, idi tor
productivit: l. ', re bound the Revenue Group ;?.~; viSt ectio~ c onducts too fee:!
audits o f ccr? nerci?' l carriers, rssu- 1 t i n ? i'n p9: er- xial Icsz assessrents 2f up ' t:, li1O. C x i7 o z per year, I t. : e S e c - ~ i c r ?~~ Y O~ C P ~ ? ! J ~ C Sf ~ Sr~ ? F ( J ~ ~ E C
acccuats ;- r: clue; t :? ave c~ useilr ? % yP C C S ~: S: ~ ,: t B P X C !~; lc + ea Fro3 suai t , 3rii
7 . t h i s ? ay r= iuuce taxpayer i n c e ~ t i v e tt? rfoor- t l: axes properly. tic? ~ I S C
disc~: sst :; e potcnti=, l i sss o f !? ore t3an $ 7 . -: { 1~ 1 fnvi: i n revenue resill tiR G
from assign!. n~ audi. tcrs to duties other t: x! n luditin?, and we recormend
ways t o vax- izize auditor productil~ ityt hro:! g~ : l, gtomstion.
I4y staff and I xi11 be pleased t o disctiss ar clarify i t m s i n the report.
DougF.& s E. :! orton
Audi tor General
Staff: > ti1 1 i am Thornson
;+ lark Fl emi ng
Ifartha 5. Dorsey
Jerome E. Xi1 ler
Kurt L. Schul t e
2700 NORTH CENTRAL AVE. SlJlTE 700 PHOENIX, ARIZONA 85004 ( 602) 255- 4385
The Office of the Auditor General has conducted a performance audit of the
Arizona Department of Transportation ( ADOT) Motor Vehicle Division's
Revenue Group, in response to a July 26, 1985 resolution of the Joint
Legislative Oversight Committee. This performance audit i s one in a
series of audits on ADOT and was conducted as part of the Sunset Review
set forth in Arizona Revised Statutes ( A. R. S. ) § § a1 - 2351 through 41 - 2379.
The Revenue Group serves as the revenue processing arm of the Motor
Vehicle Division ( MVD) . The Revenue Group handles a1 1 revenues resulting
from A. R. S. Ti t1 e 28 ( transportation code) : approximately $ 424 mil 1 ion
annually. The major duties of the Revenue Group are to: 1) set up and
monitor commercial carrier accounts to ensure compliance w i t h Title 28 and
other requirements; 2 ) receive, process and distribute a1 1 Tit1 e 28 tax
and license revenues; and 3) audit commercial vehicle and distributor tax
accounts to ensure proper tax reporting.
Additional Audit Staff Could
Generate Millions of Dollars in Revenue-
For the Highway User Revenue Fund ( see pages 5 through 12)
The Revenue Group Audit Section does not conduct enough audits of
commercial carriers. Currently the Section audits only about 2 percent of
i t s accounts annually, resulting in potential lost assessments of as much
as $ 10.9 million per year. While audit coverage varies from s t a t e t o
state, Arizona's falls below that of several other states in a t least two
tax types.
Expanded audit coverage would substantial ly increase audit collections and
improve compliance with Arizona tax laws. Increasing the Section's
current coverage t o 3.1 percent woul d produce approximately $ 1.5 mil 1 ion
in additional assessments, and could be accomplished with current staffing
levels by implementing the productivity improvements recommended in
Finding I I I ( page 17). Increasing coverage to the 10 percent 1 eve1 woul d
require 38 additional auditors, b u t could result in an additional $ 10.9
million in assessments. The Audit Section should develop a plan to
increase audit coverage and use the plan to request funding for needed
staff.
Current Audit Selection Procedures
Are Not Effective ( see pages 13 through 18)
The Audit Section's effectiveness i s reduced by poor audit selection
procedures. Currently, audits are selected based on individual , often
arbitrary judgment and are not selected randomly. As a result, the Audit
Section has audited 57 percent of the largest accounts we analyzed at
least once in the past three years. Flany of the largest accounts were
audited repeatedly. The other 43 percent of large accounts and 96 percent
of the remaining accounts we analyzed have not been audited. Because the
Section focuses i t s efforts on a 1 imited number of large accounts, most
other taxpayers have l i t t l e incentive t o report their taxes properly. For
example, one carrier who was reporting a zero monthly tax l i a b i l i t y was
assessed more than $ 37,000 as the resul t of an audit. Such underreporting
could be causing the State to lose substantial tax revenue.
To improve the effectiveness of i t s audit coverage, the Audit Section
needs to develop selection criteria that ensure random coverage of
accounts. Management should also review accounts to determine factors
upon which selection could be based, including account size, to further
maximize revenue recovery.
The Revenue Grow Could Generate
Additional ~ evenue By Increasing The
Productivity Of I t s Audit Section ( see pages 19 thrcugh 27)
The Audit Section could increase revenue recovered through audit
assessments by approximately $ 1.8 mil 1 ion to $ 2.8 mil 1 ion annual ly by
limiting special project assignments and automating auditor duties.
Currently, auditors spend approximately 35 percent of their time on
nonaudit duties. Using auditors for special projects has cost the State
approximately $ 4.3 mill ion in the past three years, because the audi tcrs
were not using their time t o generate audit assessments. MVD should limit
use of audit staff for special projects.
The Audit Section could further increase productivity and generate more
revenue by automating several audit processes. The experience of other
audit organizations shows that the use of personal computers by auditors
can decrease the time needed to complete each audit by 10 t o 30 percent.
This trans1 ates i nto additional audits with an estimated $ 351,000 to
$ 1.3 mill ion in potential audi t assessments. The Leaisl ature should
consider funding the Audit Section's 1987- 88 budget request for eight
microcomputers and software. Eased on MVD's progress in implementing a
computerized audit program, the Legislature should consider funding
additional requests for computers in subsequent years.
The Audit Section Lacks Adeauate Controls
To Ensure Qua1 ity And integrity O f Audit
tdodifications And Taxpayer Bil i ings ( see pages 29 through 33)
The Audit Section does not have adequate controls to ensure accurate,
justifiable audit assessment modifications and bi 11 ings. Documentation to
support audit assessment modifications reviewed by our staff was either
weak or not available, even though the modifications resulted in
reductions of the original assessment amount and ranged from approximately
$ 500 to $ 368,000. Further, MVD audit supervisors did not sign- off on most
of the modifications after the completion of each audit. The Audit
Section also lacks adequate controls over assessment notifications, since
individual auditors have control over both the audit and the taxpayer
billing.
The Audit Section needs t o enforce existing standards and policies
governing assessment modifications and taxpayer notifications to ensure
that a1 1 modifications are adequately documented and reviewed. ADOT's
Internal Audit Secticn shoul d periodically review the PIVE Audit Section's
internal control s over modifications and taxpayer notifications to ensure
that they are adequate and are working as intended.
MVD Could Reduce Growth In The Number Of
Uncollectible Accounts ( see paaes 35 throuah 371
The Revenue Group has difficulty collecting monies owed from commercial
carrier accounts after a1 1 a1 1 owabl e coll ections procedures have been
attempted. In order to prevent an increase in the number of such
outstanding accounts, the Revenue Group could implement various monitoring
procedures. For example, MVD could use a local publication to track
in- State accounts entering bankruptcy proceedings so the State can f i l e as
a creditor before bankruptcy proceedings are final. MVD could also
improve i t s ability to identify out- of- State accounts that may go bankrupt
by monitoring the financial reporting of all carriers in and out of the
State. I t could also use an outside collection agency to track bankrupt
out- of- State carriers.
TABLE OF CONTENTS
Page
INTRODUCTION AND BACKGROUND . . . . . . . . . . . . . . . . . . . . 1
FINDING I: ADDITIONAL AUDIT STAFF COULD GENERATE
MILLIONS OF DOLLARS IN REVENUE FOR
THE HIGHWAY USER REVENUE FUND . . . . . . . . . . . . . . . . .
Low Audit Coverage Could Mean
Sizeable Revenue Loss . . . . . . . . . . . . . . . . . . . . .
Increasing Audit Coverage Would Generate
Substantial Additional Revenue . . . . . . . . . . . . . . . .
Recommendations . . . . . . . . . . . . . . . . . . . . . . . .
FINDING 11: CURRENT AUDIT SELECTIOh1 PROCEDURES ARE NOT EFFECTIVE. . . . . . . . . . . . . . . . . .
Audit Selection C r i t e r i a Are Poor . . . . . . . . . . . . . . .
Unaudited Accounts Are Not Encouraged To Report Correctly. . . . . . . . . . . . . . . . .
Audit Selection Procedures
NeedToBeImproved . . . . . . . . . . . . . . . . . . . . . .
Recommendations . . . . . . . . . . . . . . . . . . . . . . . .
FINDING 111: THE REVENUE GROUP COULD GENERATE
ADDITIONAL REVENUE BY INCREASING THE PRODUCTIVITY OF ITS AUDIT SECTION . . . . . . . . . . . . . . .
Special Projects Reduce
P o t e n t i a l A u d i t Revenue . . . . . . . . . . . . . . . . . . . .
Automation Would Increase P r o d u c t i v i t y
And Produce More Revenue. . . . . . . . . . . . . . . . . . . .
Recommendations . . . . . . . . . . . . . . . . . . . . . . . .
TABLE OF CONTENTS
Page
FINDING IV: THE AUDIT SECTION LACKS ADEQUATE
CONTROLS TO ENSURE THE QUALITY AND INTEGRITY
OF AUDIT MODIFICATIONS AND TAXPAYER BILLINGS. . . . . . . . . . 2 9
Audit Section Needs to Strengthen
Controls Over Modified Assessments. . . . . . . . . . . . . . . 29
Controls Are Needed Over
Taxpayer Notifications. . . . . . . . . . . . . . . . . . . . . 3 1
Recommendations . . . . . . . . . . . . . . . . . . . . . . . . 32
FINDING V: THE MOTOR VEHICLE DIVISION
COULD REDUCE GROMTH IN THE NUMBER
OF UNCOLLECTIBLE ACCOUNTS . . . . . . . . . . . . . . . . . . . 35
MVD Could Minimize the Growth of Uncol lectibl e
Accounts Through Monitoring . . . . . . . . . . . . . . . . . . 35
II4VD Has Difficulty Collecting
Money Owed For Certain Accounts . . . . . . . . . . . . . . . . 3 6
Recommendations . . . . . . . . . . . . . . . . . . . . . . . . 37
OTHER PERTINENT INFORMATION . . . . . . . . . . . . . . . . . . . . 39
MVD Collections U n i t Has Increased
Collection Of Past Due Accounts . . . . . . . . . . . . . . . . 3 9
Abatement Of Uncollectible Accounts . . . . . . . . . . . . . . 4 0
AREAS FOR FURTHER AUDIT WORK. . . . . . . . . . . . . . . . . . . . 4 1
AGENCYRESPONSE . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3
LIST OF TABLES
TABLE 1 - Personnel Assigned t o MVD Revenue
Group As O f March 1986. . . . . . . . . . . . . . . . . . 2
TABLE 2 - Fuel Use Tax Audit Coverage Comparison
July 1, 1983 Through June 30, 1384. . . . . . . . . . . . 7
TABLE 3 - Other Taxes Audit Coverage
Selected States - 1985 Data . . . . . . . . . . . . . . . 8
TABLE 4 - P o t e n t i a l Annual Assessments From Increased Coverage. . . 10
TABLE 5 - Percentage o f Auditor Time Assigned And
Revenue Lost Due To Special Project
Assignments For Fiscal Years
1982- 83 Through 1984- 85 . . . . . . . . . . . . . . . . . 2 0
LIST OF FIGURES
FIGURE 1 - Projected Increases i n Audit Revenue
Through P r o d u c t i v i t y Gains . . . . . . . . . . . . . . .
INTRODUCTION AND BACKGROUND
The Office of the Auditor General has conducted a performance audit of the
Arizona Department of Transportation ( ADOT) Motor Yehicl e Division ' s
Revenue Group in response t o a July 26, 1985, resolution of the Joint
Legislative Oversight Committee. This performance audit i s one in a
series of audits on ADOT, and was conducted as part of the Sunset Review
set forth in Arizona Revised Statutes ( A. R. S. ) $ 541- 2351 through 41- 2379.
The Revenue Group serves primarily as the revenue processing arm o f the
Motor Vehicle Division ( MVD). The Revenue Group monitors and collects a1 7
revenues resul t i ng from A. R. S. Title 28 ( transportation code), averaging
approximately $ 424 million annually over the past tvlo years. Title 28
revenues include gas and other fuel taxes, commercial carrier taxes,
drivers V icense fees, and vehicle 1 icense plate, t i t l e and registration
fees.
Ttie Revenue Group has three major functions carried o u t by i t s three
sections as described below.
o Compliance Control : Responsible for setting up and monitoring
accounts t o ensure that all co~ mercial vehicle operators are in
compl iance with Title 28 requirements, and rules and rea- ul ations
governing registration and taxation. Thi s includes opening
accounts and determining the appropriate registration fees and
tax and bond amounts.
o Receivables Control : Responsible for receiving and processi~ g
all Title 28 tax and fee payments, accounting for, reporting and
distributing these revenues, and collecting delinquent payments.
o Audit: Responsi b1 e for enforcing co~ rnercial vehicl e and
distributor tax laws by auditing accounts t o ensure proper tax
reporting.
The three sections conduct various activities t o ensure commercial carrier
compliance and remittance of monies owed t o the State. For example, the
Compliance Control Section reviews potential new applicants and renewals
t o ensure proper licensure and appropriate bonding levels. This can
include a yearly review of carriers' bonding levels based on the dollar
amount of business to verify i f the bonds are correct. The Receivables
Control Section processes and accounts for all Revenue Group monies. This
section monitors each motor carrier use fuel tax report which i s filed to
ensure that a specified ratio exists between the motor carrier tax and use
fuel tax. If, for any reason, t h i s r a t i o does not exist, i t signals a
potential noncomplier and the report i s forwarded to the Revenue Group
collection unit for follow- up. The Audit Section provides the final
check. An audit i s the most comprehensive and effective of all the
processes performed.
Staffing And Budget - The Revenue Group's budget i s not separate from the
the budget for the Motor Vehicle Division of ADOT. However, staffing
figures for the three sections pl us the Revenue Group's admi ni s t r a t i on are
presented in Tab1 e 1.
TABLE 1
PERSONNEL ASSIGNED TO MVD REVENUE GROUP AS OF JUNE I986
Budgeted Budgeted Temporary/ Seasonal
FTEs Positions Filled Clerical Pool Empl oyees
Compliance Control 39 3 1
Receivabl es
Control 3 7 2 9
Audit 22 ( I 1 19
Administration - 2 - 2
TOTALS
) This figure includes 17 auditors, one manager, tv: o supervisors and
two support staff.
Source: MVD Revenue Group data.
Scooe Of Audit
Our audit of the MVD Revenue Group focused primarily on the effectiveness
and efficiency of the Revenue Group's Audit Section. Ne focused on the
A u d i t Section because the Revenue Group i s i n the process of designing and
implementing an automated system that will affect most operations in the
Compl iance Control and Receivables Central Sections. The audit addressed
the following specific issues.
s Whether current audit coverage i s sufficient;
e The effectiveness of current audit selection procedures;
Ways t o maximize auditor productivity;
o The adequacy of audi t modi f icati on documentation and supervisory
review, and of certain procedures governing taxpayer billings;
and
s Whether MVD can reduce the growth in the number of uncollectible
accounts.
The report section titled Other Pertinent Information addresses the
productivity of the Revenue Group's collection activities and problems
concerning the abatement of uncol lectibl e 1 iabil i ties.
The Auditcr General and staff express appreciation to the Director of the
Department of Transportation and his s t a f f , and specifically to i4VD's
Revenue Group, for their cooperation and assistance during the course of
tne audit.
ADDITIONAL AUDIT STAFF COULD GENERATE MILLIONS OF DCLLARS IN REVEF! UE FOR
THE HIGHWAY USER REVENUE FUND
The Revenue Group Audit Section does not conduct enough audits of
commercial carriers. Currently the A u d i t Section audits only about
two percent of i t s accounts annually, resulting i n a backlog of
approximately 3,100 unaudited accounts per year. Whil e audit coverage
varies among s t a t e s and among different types of taxes, Arizona's coverage
of a t l e a s t two tax types i s less than the average of other states.
Assigning nore audit s t a f f t o commercial c a r r i e r audits would increase
audit coverage and could resul t i n up to $ 10.9 million per year i n
additional audit assessments.
The Audit Section i s charged w i t h auditing accounts for several different
taxes paid by commercial motor c a r r i e r s , fuel vendors and distributors.*
Taxpayers may be required by law to pay several types of commercial
vehicle taxes. All taxes paid are deposited i n the Highway User Revenue
Fund. A taxpayer's account may consist of more than one tax type. Each
tax type on a taxpayer's account i s referred to as an account type. As of
June 1986, 22,000 taxpayers paid taxes in more than 39,000 account types.
Also as of June 1986, the A u d i t Section employed 17 full- time auditors.
Low Audit Coverage Could
Nean Sizable Revenue Loss
The level of audit coverage achieved by the Audit Section appears to be
inadequate. The Section audits only a small portion of i t s accounts each
* The Audit Section i s responsible for ten different tax and revenue
types: 1 ) use fuel user, 2 ) use fuel vendor, 3) use fuel restricted
vendor, 4) weight distance, 5) gross receipts, 6 ) motor vehicle fuel
distributor, 7 ) motor vehicl e fuel r e s t r i c t e d d i s t r i b u t o r , 8)
international fuel tax agreement, 9) international registration pl an,
10) prorate. According to an MVD supervisor, two types - use fuel
user and weight/ distance ( motor c a r r i e r ) - accol; nt for 82 percent of
the accounts and 52 percent of the assessments.
year and has a substantial backlog of unaudited accounts. Arizona's
percentage of accounts audited is low compared w i t h other states.
Low audit coverage - The Audit Section audits only about 2 percent of the
total number of account types each year. The Section has completed an
average of only 802 audits of account types per year over the l a s t three
years, while the total tax load continues to grow and is now more than
39,000 account types. The 802 audits t r a n s l a t e i n t o approximately 500
taxpayer accounts audited per year out of a total population of 22,000
taxpayers.
The low audit coverage means that the Motor Vehicle Division ( FWD) may be
losing potential revenues because so few accounts are audited each year.
More than 14,000 taxpayer accounts have not been audited w i t h i n the l a s t
30 months, which t r a n s l a t e s i n t o more than 24,700" separate audits of
account types. Based on our suggestions regarding a more appropriate
level of audit coverage, FIVD's backlog coul d be as much as 3,100 accounts
per year. This results i n a loss of up to $ 10.9 million annually i n
potenti a1 assessments ( see page 10).
The backlog also means that many otherwise collectible funds niust go
uncollected, because taxpayers are required in most cases to maintain
records for only three years. Thus, failure to audit i n three years
results in potential revenue that may never be collected.
Coverage i s higher in other s t a t e s - ! dhile audit coverage varies from
s t a t e t o s t a t e and among the various tax types, Arizona's performance
f a l l s below that of several other s t a t e s ' actual performance for two major
Arizona tax types.
j; Although I4VD currently has more than 39,000 account types, the 24,700
unaudited in the l a s t 30 months include only accounts that are over 30
months old and have not been scheduled for audit. The remainina
14,300 accounts incl ude accounts establ i shed wi thi n the previous 3G
months, the approximately 2,400 accounts audited during the past 30
months, and accounts scheduled for audit that have not yet keen
audited.
A t least 13 other s t a t e s are auditing a greater percentage of fuel usage
tax account types. Table 2 shows Arizona i n comparison to the six highest
states and the 35 state average. A t l e a s t four states audit a
significantly greater percentage of weight or mileage account types, as
shown in Table 3, page 6.
TABLE 2
FUEL USE TAX AUDIT COVERAGE COMPARISON
JULY 1 , 1 983 THROUGH JUNE 30, 1 984
Carriers Registered Fie1 d
Rank s t a t e ( 1) For Fuel Use Tax Audits Percentaae
1 Mary1 and 33,116 3,180 9.6
2 Kentucky 29,240 1,808 6.2
3 S. Dakota 9,624 480 4.9
4 Texas 20,100 7 54 3.8
5 Washington 13,588 461 3.4
6 I orva 24,700 81 2 3.3
Arizona
Average for 35 States Surveyed 1.9
Colorado was eliminated from the ranking because of its manner of
counting audits. Audits covering more than one year are mu1 t i p l e
counted.
( 2 ) This number was obtained from MVD and not the bIGA study, since b1VD
had originally supplied incorrect data to the MGA.
( 3) Maine also had 1.3 percent coverage.
Source: Compiled by Auditor General s t a f f from " State A u d i t and
Enforcement Practices ," Report !! o. 9 of the National Governors '
Association Project on Uniform State Procedures for Interstate
Motor Carrier Taxation and Regul ation.
TABLE 3
OTHER TAXES AUDIT COVERAGE FOR SELECTED STATES
JULY 1, 1983 THROUGH JUNE 30, 1984
Carriers Registered Fie1 d
State For Other Taxes Audits Percentage
Oregon
Nevada
Kentucky
Idaho
Arizona
Average for 11 states surveyed 4.1
Other taxes are imposed based on weight and mileage, gross receipts
and mileage, mileage alone, or the number of axles on the vehicle.
Source: Compiled by Auditor General staff from " State Audit and
Enforcement Practices," Report No. 9 of the National Governors'
Association Project on Uniform State Procedures for Interstate
Motor Carrier Taxation and Regulation.
According to Tab1 e 2, the state of Maryland's fuel use audit coverage i s
more than seven times as high as Arizona's. Kentucky's coverage i s almost
five times as high, and a t least 12 other states exceed Arizona's use fuel
tax audit coverage rate. Table 3 shows more rate variances, with Oregon's
weight or mileage tax audit coverage more than seven times and Nevada's
more than six times higher than Arizona's.
Althougl- r there is no recognized standard that specifies an adequate level
of audit coverage, MVD has not established i t s own goals for both coverage
level and revenue recovery. For these reasons, the Audit Section needs to
establish an audit plan that sets coverage and recovery goals. For
example, the Section may want t o consider the 10 percent level suggested
by a National Governor's Association ( NGA) study for home- based interstate
accounts in the International Registration Plan ( IRP). A1 though this
level i s intended only for IRP accounts, Arizona's low overall coverage
combined With the potential high dollar amounts that could be recovered
may make 10 percent a worthwhile goal t o attain.
Increasing Audit Coverage Would Generate
Substanti a1 Additional Revenue
Increasing the Audit Section's coverage ~;! oudl substantially increase audit
collections. However, the Audit Section needs to develop a plan for
increased coverage before any staff are added.
Additional collections - If the Audit Section were to increase i t s current
audit coverage, it could recover substantial additional revenue. The
Section could increase i t s coverage t o 3.1 percent without adding staff.
Increasing beyond 3.1 percent would require additional staff b u t would be
cost effective.
Improving Audit Section productivity could increase audit coverage without
additional personnel . According to ADOT productivity figures, each
auditor has 1,598 hours of avai 1 able time each year. * However, this 1 eve1
i s seldom attained because auditors are frequently assigned to special
projects. The special projects take away from direct audit time and audit
coverage suffers as a result. El iminating special project assignments and
automating several auditor functions ( see Finding I 11, page 17) cculd
increase coverage t o 3.1 percent without adding staff, as shown in Table 4
( page 10).
Audit staff are cost effective because each auditor produces more revenue
than i s expended on salary and related expenses. A t maximum productivity,
the average Audit Section auditor could produce more than $ 249,000 in
audi t assessments per year. ** The average audi tor ' s sa1 ary and re1 ated
expenses are $ 28,429. Thus, each additional auditor could result in a net
* There are 1,776 direct hours available, b u t FIVD excluded travel tine
when calculating assessments per hour. Our analysis indicates t h a t
travel time i s approximately 10 percent. Thus, we used 1,59E hours to
calculate potential audit assessments.
** Annual assessments are based on the average o f $ 3,408 per audit. This
figure is based on current figures of $ 142/ hour times 24/ hour audit =
$ 3,408. New figures based on improved productivity are $ 3,408 divided
by ( 24 times 0.9) = $ 156/ hour. The 90 percent figure i s used because
i t takes only 90 percent as long t o do an audit with automation. The
dollars per hour increase as hours per audit decrease.
increase of more than $ 220,000 i n potential assessments. Even a t the
A u d i t Section's current average level of 60 percent d i r e c t a u d i t time, an
additional auditor would produce a net increase of $ 132,000 i n assessments.
Expanding MVD's audit s t a f f is, therefore, a cost effective means of
producing revenue for Arizona's transportation programs. Tab1 e 4 a1 so
shows several p o s s i b i l i t i e s f o r increased staff and audit assessments.
TABLE 4
POTENTIAL ANNUAL ASSESSMENTS FROM INCREASED COVERAGE
I
Number of Amount of
Auditors Coveraae Assessments Increase
Present 17 2.0% $ 2,733,216
Proposed ( 2 ) 17 3.1 4,208,880 $ 1,475,664
28 5.0 6,965,952 4,232,736
55 10.0 13,683,120 10,949,904
) This is the current level of staffing as of June 1986.
( 2 ) These a1 ternatives assume 1,598 hours of direct audit time and a 10
percent increase in productivity through automation. ( See Finding
111, pages 19 through 27 for an explanation of possible increases i n
A u d i t Section efficiency. )
Source: Compiled by Auditor General s t a f f from A u d i t Section data and
National Governor's Association data.
Our estimates of potential additional revenue recovery are based on the
assumption that the A u d i t Section would generate the same average revenue
per audit hour as i n the past three years even as the number of audits
increased. Authorities note that i f audit selection systems are working
effectively, dollars generated per audit will decline as tax base audit
coverage increases. Thi s occurs because the 1 argest and most productive
accounts are audited f i t- st, 1 eaving 1 ess productive accounts for
subsequent selection. However, as noted in Finding I1 ( page 11), the
Audit Section i s not currently selecting the most productive accounts for
audit. T h u s , improvement i n audit selection may offset any expected
declines i n average collections per audit, a t l e a s t during the f i r s t few
years. The eventual lower assessments ivould s t i l l result i n a revenue
gain because more taxpayers would pay their true 1 iabil ity.
Audit plan needed - The Audit Section needs t o develop a plan for
increasing audit coverage. The plan should focus on the best means for
reducing the backlog through increased productivity and additional staff.
Any kind of expanded coverage beyond that gained through enforcing
100 percent direct audit time for all auditors and automating audit tasks
would require more audit s t a f f , and these staff need to be carefully
phased into the operation. Audit Section management feel that they could
hand1 e up to 20 new staff a t a time as long as there was one supervisor
for every five to seven auditors. However, given the current state of
change within the Section, this may not be possible. Eight to ten new
auditors a year for several years i s perhaps a more appropriate estimate.
MVD i s receiving more auditors, b u t on a limited basis.
ADOT has requesxed some additional auditor positions. The t4VD Revenue
Group submitted a request for 18 auditors in the fiscal year 1986- 87
budget. Five of these positions were submitted by ADOT for legislative
approval. All five positions were funded. ADOT's five year strategic
budget plan has a request for three additional auditors i n fiscal year
1988- 69. ADOT i s also planning to contract some audits. The 1886- 87
budget includes $ 39,000 to fund a pilot project that would involve
contracting with a public accounting firm in Los Angeles. The accounting
firm would perform revenue audits of Arizona tax accounts domiciled in Los
Angeles and the surrounding area.
The level of audit coverage achieved by the Audit Section i s low. This
low coverage could bz costing the State millions of dollars in lost
revenue, and does n o t ensure ccmpliance by the carriers. The Audit
Section needs to develop goals for increasing coverage an@ compliance, and
out1 ine a plan for staff and resources necessary for attaining these goal s.
1 . The Audit Section needs t o develop a plan to increase audit coverage.
Specific objectives should be developed to establish the level of
coverage and the number of audits that need t o be done to meet these
goals. This plan should outline the additional staff and resources
needed, how they are to be phased into this increased effort, and the
time table for implementation. An estimate should be made of the
anticipated additional revenue the effort will bring.
2. ADOT should use this p1a. n in formulating i t s budget and request
funding for the auditor positions to carry out the plan.
3. The Legislature should consider funding additional auditins positions
for MVD in accordance with the plan developed by the Audit Section.
FINDING I1
CURRENT AUDIT SELECTION PROCEDURES ARE NOT EFFECTIVE
In addition to the problem of low audit coverage described in Finding I,
poor audit selection further reduces the Audit Section's effectiveness.
The Section has chosen to repeatedly audit a portion of the largest
taxpayers and has ignored most of the remaining taxpayers. This practice
reduces the incentive for many taxpayers to accurately report their taxes
and has resulted in the loss of potential revenue through underreporting.
To improve i t s effectiveness, the Audit Section should develop a more
systematic selection process.
A~ dti Selecticn
Cr1 t e r ~ aA re Poor
Current audit selection criteria 1 imit the Motor Vehicle Division's ( f 4 V D )
ability t o maximize compliance and revenue recovery. These criteria are
hishly judamental , arbitrary and 1 ack randomness. As a resul t, certain
accounts are audited cn a regular basis while other accounts are virtually
i gnored.
Current selection procedures a1 1 ow Audit Section personnel considerable
subjectivity - in selecting accounts for audit. A1 though IiVD's primary soal
i s t o audit larger acccunts, the audit staff a1 so use other criteria which
i ncl ude past audit results, reporting problerns and the account hol der ' s
geographic location. While some of these criteria may have objective
merit, the lack of any formal system or guidelines means that the chance
of being selected for audit varies widely from one account t o another.
This i s due in part t o the fact that individual auditors, in effect,
select many of the accounts t o be audited. A1 t h o ~ i g h the ultimate
authority for deciding which accounts \ rill be audited lies with the audit
manager, he usual ly assigns audit sel ection responsi bi 1 i ty t o an audit
supervisor who in turn assigns i t to a staff auditor.
As a result, the ! IVD Audit Section has emphasized certain large accounts
i n the sel ecticn process. These accounts are audited r e y l arly, primarily
because audit resources are limited and previous audits have resulted i n
large assessments. Overall , 57 percent of the largest* accounts we
analyzed** have been audited a t l e a s t once and, according to A u d i t Section
management, many have been audited repeatedly. The other 43 percent of
large accounts and 96 percent of the remaining accounts we analyzed were
not audited i n a t least the l a s t 30 months.***
Unaudited Accounts Are Not
Encouraged To Report Correctly
The Audit Section's poor selection procedures appear to have resulted i n
underreporting among some taxpayers. Because the Audit Section focuses
its e f f o r t s on a limited number of large accounts, most taxpayers have
l i t t l e incentive to report t h e i r taxes properly. In fact, several
instances have surfaced in which taxpayers were underreporting their
actual 1 iabil i t i e s . Underreporting may cause the State to 1 ose
substantial highway revenue and a1 so results i n inaccurate management
information regarding actual account size.
L i t t l e incentive to r e ~ o r t properly - Through its poor selection
procedures, the Audit Section is, i n effect, providing unaudited account
holders w i t h 1 i t t l e incentive to properly report taxes owed. Some
trucking companies may decide to underreport ( and save money) because they
know the risk of being audited is low. Therefore, the A u d i t Section's
selection policies may actually encourzge taxpayers to underreport.
Analysis of MVD audit results by Auditcr General staff suggests that some
carriers do underreport. We analyzed a random sample of audi tea accounts
by correlating account size and assessment amount for each account in the
* Largest accounts are defined as those with an average monthly
1iabilit. y of more than $ 5,000.
** Our analysis included a l i active acccunts that have a t least one of
the vendor, fuel use, or motor carrier tax types. We therefore
analyzed more than 17,000 accounts, or more than 77 percent of f1VD's
t o t a l active accounts as of 12- 13- 15.
*** The Audit Section's records only cover the past 30 ~ ionths. Thus, we
were unable to determine how often the audited accounts had been
audited or how long unaudited accounts had existed without an audit.
sample.* The results of t h i s correlation clearly show that there i s s
very weak relationship between account size and assessment amount.** In
short, large assessments could result from smaller accounts i n the
population as well as from the larger accounts.*** The reason for t h i s
relationship may be that some smaller accounts are, i n f a c t , small only
because the taxpayer underreports actual tax l i a b i l i t i e s .
Specific instances of underreporting - Although complete data is not
available, several accounts i n the population clearly indicate that
" small" accounts may i n fact be larger than reported to be. The following
are examples of substantial audit assessments resul ting from reportedly
small er accounts.
e One carrier who was reporting a monthly l i a b i l i t y of zero was
assessed more than $ 37,000 as the r e s u l t of an audit.
9 A carrier who reported $ 1,400 i n monthly l i a b i l i t i e s was assessed
$ 1 9,400 during an audit.
a A carrier whose reported ri: onthly l i a b i l i t i e s were just under
$ 2,500 was assessed $ 31,200 a f t e r an audit.
These examples were disccvered by the T. 1VD Revenue Group and clearly
i l l ustrate the potential for underreporti ng. Cur correl ation analysi s
a1 so indicates the possi bi l i ty that sucn underreporti ng i s taking pl ace
because the larger assessnents were found in the smaller accounts.
* The sample consisted of 169 audited accounts of the total cf 759
active audited accounts as of December 13, 1985, that had a t l e a s t one
of the vendor, fuel use or motor carrier tax types. The sample of 169
yielded a 95 percent confidence level w i t h a r e l i a b i l i t y of -+ 3
percent.
** The correlation derived was . I991 a t the .01 level o f significance,
therefore indicating a very weak re1 ationship.
*** The rreak correlation a1 so suggests that those large accounts that have
been audited repeatedly may be improving their tax reporting. The
closer a taxpayer comes to reaching full complia~ ce ( i . e . , accurate
tax reporting), the lower the audit assessment.
Improper reporting means reduced revenue - Underreporting could be causing
the State to lose substantial tax revenue. A1 though i t bias not possible
to precisely estimate the amount of l o s t revenue, our correlation suggests
that unaudited accounts have the potential for sizeable assessments.
In addition, improper reporting reduces the Audit Section's attempts to
maximize revenue recovery. The Section's assumption that 1 arge
1 iabil i t i e s would lead to 1 arge assessments seemed 1 ogical because big
companies do more business and incur larger l i a b i l i t i e s which usually
result in larger assessments. However, such an assumption depends upon
accurate identification of companies with large 1 iabil i ties. Accurate
identification of a1 1 such companies i s unl i kely without proper reporting
of tax l i a b i l i t i e s .
Audit Selection Procedures
heed To 8e Im~ rcved
The Audit Section needs to develop procedures for selecting audits that
wi 1 1 improve taxpayer reporting. These procedures shoul d i ncl ude
oversampling of large accounts that have not been previously audited and
random sampling of small accounts. Once this has been accomplished other
potentially productive accounts should be oversampled. The Tax and
Revenue Group Automated Tracking System ( TARGATS) i s intended to
facilitate many of these improved procedures, b u t an interim system i s
needed.
To improve the effectiveness of the expanded audit coverage recommended i n
Finding I ( page 5 ) , the Audit Section needs t o develop selection criteria
that ensures greater coverage of unaudited large accounts and random
coverage of a1 1 accounts. With improved selection techniques, audits of
large accounts that have not previously been audited are likely t. o produce
large assessments and help ensure future compliance by major taxpayers.
A t the same time, however, the Audit Section needs t o ensure that all
other taxpayers comply with commerci a1 carrier tax 1 aws through proper
reporting of 1 iabil i ties. Random sampl ing of accounts i s particularly
important because of the underreporting identified by previous EflVD audits
of reportedly smaller accounts that were actually larger than expected.
Whil c these procedures are being imp1 emented, management should
concurrently focus on other potentially productive accounts to further
maximize revenue recovery. Managettent may wish to examine accounts based
on secondary criteria t o determine which accounts should be targeted t o
increase the Audit Section's abil ity to ensure proper reporting and
maximize revenue recovery. Possible criteria coul d be those accounts with
a history of reporting problems ( i. e. reporting zero l i a b i l i t y , failure to
report a t a l l , major record keeping errors uncovered on previous audits),
and accounts that are facing bankruptcy. Other factors to consider could
be changes in company personnel ( i. e. new bookkeeper) and statutory
changes.
The Revenue Group's plans t o improve i t s audit selection criteria appear
adequate b u t will not be implemented for approximately one year. The
criteria planned for the TARGATS system appear to take into consideration
both accwate reporting ( random se1 ecti on) and revenue recovery
( oversampl ing of 1 arge and other potential ly productive accounts).
However, the Audit Section does not plan to implement the TARGATS
selection criteria until September 1987. In the meantime, blVD will
continue to 1 ose potential revenue. The Audit Section should, therefore,
implement these criteria before TARGATS i s brought on line.
Audit Section selection procedurgs may not effectively ensure compl iance
with Arizona tax laws. Consequently, the State could be losing revenue
needed for highway construction and mai~ tenance. Improved selection
procedures are needed t o improve compliance and maximize revenue recovery.
RECOI. lf. iEF! DATI ONS
1. The Audit Section should improve audit selection by:
a. Selecting audits randomly from the entire population of
taxpayers. The Section should implement random selection before
TARGATS is brought on line.
b. Once random selection i s achieved, management shoul d eval uate
various characteristics of i t s accounts t o determine which
accounts would likely result in the greatest potential revenue
recovery. Such characteristics may include account size,
reporting problems, organizational changes within the company,
account age, and period of time since the account was l a s t
audited. If account size i s considered, the Audit Section should
identify large accounts that have n o t been audited and designate
a portion of i t s audit resources to ensure that these accounts
are audited in a timely manner.
THE MOTOR VEHICLE DIVISION REVENUE GROUP COULD GENERATE ADDITIONAL REVENUE
BY INCREASING THE PRODUCTIVITY OF ITS AUDIT SECTION
The Motor Vehicle Division ( MVD) Revenue Group Audit Section could
increase audit assessments by approximately $ 1.8 mil lion to $ 2.8 mill ion
annually through improved Audit Section productivity. Reducing the amount
of time auditors currently devote to nonaudit activities would enable MVD
t o increase audit assessments by more than $ 1.4 million annually. Use of
microcomputers for fie1 d audits woul d a1 so improve individual auditor
productivity, and coul d resul t in additional assessments of $ 351,210 to
more than $ 1.3 mil 1 ion annual ly .
Speci a1 Projects Reduce
Potential Audit Revenue
Use of audit staff for special projects limits the audit assessments
generated by the MVD Audit Section. Time spent on nonaudit projects
durirrg the past three fiscal years cost the State more than $ 4.3 million
in lost assessments. EVD could take several steps t o reduce these losses.
The major duty of the Audit Section i s t o ensure proper payment of taxes
and fees incurred by ccrnnercial carriers. Auditors conduct examinations
of taxpayer/ corporate accounts and reccrds. Other activities are
considered special projects. Serving in acting management or supervisory
capacities, special task force assignments, compiling audit production
reports, and performing clerical functions such as preparing mail outs or
purging files are several examples of activities MVD defines as special
projects.
Loss of revenue - The State i s losin9 a great deal of money because
auditors are taken away from direct audit assignments and placed on
special projects. Further, because special projects require experienced
audit staff, the more complex accounts remain unaudited. Special project
assignments have increased over the last three fiscal years.
Special projects cost the State more than $ 4.3 million i n potential
revenue over the past three fiscal years, and have contributed to a
substantial back1 og of unaudited accounts. Since special projects 1 imi t
the time spent on audits, MVD must forgo potential assessments that
auditors would otherwise produce. Tab1 e 5 shows the potential revenue
losses based on the average assessment per hour from fiscal years 1983
through 1985. In addition, over the past three years the Audit Section
completed an average of only 802 audits per year out of a total of
approximately 39,000 account types.*
TABLE 5
PERCENTAGE OF AUDITOR TIME ASSIGNED AND POTENTIAL
REVENUE LOST DUE TO SPECIAL PROJECT ASSIGNMENTS
FOR FISCAL YEARS 1982- 83 THROUGH 1984- 85
Percentage of Average
Fi scal Special Project ,_, Total Audit Assessment Potential
Year Hours 1 1 1 Hours Per Audit Hour Revenue Lost
TCTAL
Annual
Average 10,101
) Figures exclude all project time charged by the acting audit manager.
( 2 ) Special project time increased i n fiscal year 1984- 85 because two
Audit Section s t a f f were assigned full- time to the TARGATS project.
TARGATS i s the Tax and Revenue Group Automated Tracking System which
will a t t e ~ p to address MVD system deficiencies through automation.
Source: Compiled by Auditor General staff from PIVD A u d i t Section data and
the Field Audit Production Report covering fiscal years 1982- 83
through 1984- 85.
* A carrier account consists of different account types ( e. g., fuel use,
motor c a r r i e r , etc. 1. All account types are subject to audit.
Special project assignments a1 so reduce the experience 1 eve1 avai 1 abl e to
the Audit Section. For example, two special projects* outside the Audit
Section are currently using four of the most experienced auditors with 28
combined years of audit experience. This loss of experience to the Audit
Section reduces i t s a b i l i t y t o complete the more complex audits and
eliminates the assessments that would have resulted from those audits.
Special project assignments account for a growing proportion of auditor
time. During the three- year period from fiscal year 1982- 83 through
1984- 85, special project assignments have increased from approximately 31
percent t o 40 percent of all auditor time, for an average of 35 percent,
as shown in Table 5.
Minimize auditor time spent on special projects - Because of the impact of
special project assignments on audit assessments, MVD should limit the use
of audit staff for these assignments. Management or clerical personnel
could be assigned t o most special projects within the Audit Section. When
audit staff must be used for extended assignments outside the Audit
Section, they should be replaced to ensure full audit coverage.
Use of audit staff for many special projects within the Audit Section
appears to be unnecessary and poorly managed. These projects are usually
of short duration and seldom require auditor expertise. Instead, these
projects could be more appropriately assigned t o an audit supervisor, the
audit group manager or t o clerical staff. Examples of special projects
incl ude: development of future audit schedules, pending cl osure account
review,** and proofreading a proposed audit procedures manual. MVD i s
presently reviewing a1 1 project assignments within the Audit Section.
Corrections will be made so future projects 1 not interfere with
regular auditor responsibilities.
* Projects include TARGATS automation and MVD assuming vehicle county
t i t l e and registration responsibilities for several counties. ** Pending closure account review was defined by Audit Section management
as a clerical function.
MVD uses audit staff on long- term special projects because these projects
require specific expertise not otherwise available in the Division.
Examples of 1 ong- term special projects include the following.
Q TARGATS Project - The Revenue Group i s developing an automated
system ( Tax and Revenue Group Automated Tracking System) to
correct systematic deficiencies in the Group's operations. A
task force was created and recommendations were made t o improve
operations. The TARGATS project task force i ncl uded an outside
CPA firm and employees of the Motor Vehicle Division. Also, an
audit manager and an auditor were selected to serve on this
project full- time. The project assignments are for five years.
The auditors were not replaced.
e Other Long- Term Projects - P4VD Revenue Group auditors often
provide professional assistance in other areas. In the past, MVD
has assigned Revenue Group auditors t o provide technical
expertise t o the Office of Audit Analysis and MVD's Pima County
Title and Registration Office. The auditors have also done
1 imi ted foll ow- up for county t i t l e and regi stration takeovers
after ADOT's Office of Audit Analysis identified problems. An
MVC auditor was also assigned, along with other ADOT staff, t o
he1 p resol ve possi bl e probl ems with Highway User Revenue Fund
monies in Pima County. The MVD auditor remained on the Pima
County project approximately a year and one- ha1 f.
MVD does n o t replace auditors assigned t o long- term projects and this
could cause substantial revenue 1 osses. According to the 11VD Assistant
Director, the Department agreed to absorb personnel costs on the TARGATS
project. As a result, when auditors were assigned they were not
replaced. Therefore, b? VD was willing to forgo the potential assessment
revenue in exchange for TARGATS, because the Director f e l t t, hat the
long- term revenue gain from TARGATS would be greater than the potential
revenue lost. However, the assignment of an audit manager and an auditor
to TARGATS for five years reduces potential audit assessments by more than
$ 477,500* annually. Projected over the five- year period, rep1 acing
auditors could pay for almost one- ha1 f of TARGATS' estimated cost.**
In the future, the MVD Director plans to assign management analysis
section personnel to special projects. However, this section i s currently
staffed with mostly clerical personnel and lacks the expertise to meet
many MVD needs. Future budget requests will seek positions for qualified
technical personnel t o staff difficult and complex projects.
Until the Department has an adequate management analysis capability and
for extended projects where audit staff is absolutely necessary, MVD
should replace any audit staff who are reassigned, to maintain adequate
audit coverage. Use of replacement staff would not only maintain the
Audit Section's ability to ensure compl iance and generate audit revenue,
b u t would also provide for skilled staff in the future.
Automation Could Increase Productivity
And Produce More Revenue
The Revenue Group Audit Section cou1 d increase productivity and generate
more revenue by automating audit processess. MVD auditors are spending an
excessive amount of time performing processes that could be completed in
1 ess time by computer. Automation reduces time consuming activity.
Manual processes hamper potenti ill prodirctivi ty - Lack of automation i s
causing MVD auditors t o be less productive, and a backlog of unaudited
accounts continues to grow. Auditors are spending a great deal of tine
repeating manual processes. Auditors expend considerable time examining
and computing all necessary audit information. Records are examined for
validation of reported information using source documents and sufficiency
of bond coverage. A t the conclusion of the examination process,
* Amount based on average audit assessment per hour of $ 149.41 ( fiscal
year 1984- 85 figure) multiplied by the standard available yearly hours
( 3,196) for two auditor positions. Although one of the transferred
positions was a manager, the net result i s two vacant auditor
positions in the Audit Section.
** Estimated cost of TARGATS implementation i s $ 5.5 million.
the auditor must organize the information gathered on various work
sheets. The auditors use this information to compute the tax assessment
and any penal ty and interest charges. A cal cul ator i s the only aid used
to complete any computations and to verify formulas that determine the
final assessment. An auditor places a1 1 the information gathered from
each audit on three separate work sheets. A personal computer would allow
an automated program to compl ete the process more quickly. Standardized
work sheets and formulas could be stored on the computer and would not
need to be recreated for each audit. The computer would recreate the
schedules and perform computations automatically, thus reducing the amount
of time i t takes to audit an account.
The Audit Section's lack of automation results in limited audit coverage.
Completing audits manually reduces the number of accounts that can be
audited. Conducting fewer audits resul t s in fewer assessments and
increases the backlog of unaudited accounts.
Automation reduces time consuming activity - The use of personal computers
would reduce the time necessary to complete an audit. The use of personal
computers in other audit organizations has increased productivity. The
Motor Vehicle Division has plans t o purchase personal computers during
f i scal year 15' 87- 88.
Financial audit entities with duties similar to the KVD Audit Section have
experienced productivity* gains of 10 percent to 30 percent using
microcomputers. For example, Wisconsin's rlVD Audit Section is responsible
for collecting and auditing motor carrier taxes. Since the auditors began
using computers productivity has increased by 20 percent or more. The
auditors use personal computers to collect specified data. Once the data
i s collected the computer disk with the information i s mailed to the
central office. The field auditors do not make the assessment. This
* Productivity i s defined as the number of audits completed during a
given peri od.
procedure is completed by clerical and management staff in the central
off ice. Since ccmputer implementation, the amount of auditor time
required i n the office to compile audit results has been reduced.
Based on Arizona's audit experience f o r f i s c a l years 1983 through 1985,
simil ar productivity gains would yield additional assessments between
$ 322,322 and more than $ 1.2 million for 1982- 83; and between $ 347,612 and
$ 1.3 million for 1984- 85, as shown in Figure 1."
FIGURE 1
Projected Increases In Assessments
THROUGH PRODUCTIVITY GAINS
2
1.9
1 .8
1.6
1983 1984 19' 85
FISCAL YEAR a 10 % 124 20% 30%
SGU~ CSC:~ inp~ lebdy Auditor General staff frcm MVD Audit Section data and
the Field Audit Production Report covering fiscal years 1982- 83
through 1984- 85.
* Based on a projected gains in audits completed, an overall
productivity gain of 10 percent could have generated an average of
$ 351,210; 20 percent could have generated an average of $ 793,500; and
30 percent an average of $ 1,361,272.
The Arizona Banking Department a1 so reports a favorable experience with
automation. Use of personal computers has increased productivity from 10
to 20 percent. However, productivity gains require training and occur
only after a phase- in period.
The Motor Vehicle Division plans to purchase personal microcomputers. The
budget request for fiscal year 1987- 88 includes funds for eight portable
computers with modem capabilities. The eight computers requested are
similar to the ones used by the state of Wisconsin. The estimated cost of
eight computers i s approximately $ 18,500. This estimate does not include
any software. I t would cost the Audit Section approximately $ 53,500 to
provide computers and software for all Audit Section staff.*
CONCLUSION
The use of auditors for special projects should be limited. The State
potentially lost approximately $ 4.3 mill ion over the last three years
because of lost audit hours. Further, manual audit processes cost the
State between $ 351,210 t o more than $ 1.3 million in potential assessments
due to unaudited accounts.
REC OI,: MEI, IDATI ONS
1. MVD should limit use of audit staff for special projects by:
a. using personnel from other sections and ADOT divisions;
b. rep1 acing auditors on extended speci a1 projects with temporary
auditors t o provide continued full audit coverage; and
c. scheduling and managing special projects within the Audit Section
so they do not interfere with regular audit assignments.
* The cost includes 20 computers with modems and LOTLIS software at
$ 2,671. This cost does not incl ude any formal software training. The
price includes computers for 17 auditors and three supervisory staff.
2. The Legi sl ature shoul d consider funding microcomputers and software
for the MVD Audit Section. The Legislature should consider providing
MVD with the funds requested in the fiscal year 1987- 88 budget for the
initial purchase of eight microcomputers. Based on MVD's progress in
utilizing i t s computers, the Legislature should consider funding
additional requests for computers in future years.
3. The Audit Section should develop procedures to i~ plement the use of
personal computers. The procedures should include obtaining correct
software and developing templates and formulas t o assist in
calculations. Auditors should be provided with formal and on- the- job
training so the computers can receive maximum usage and accounts will
continue t o be audited during phase- in.
THE AUDIT SECTION LACKS ADEOUATE CONTROLS TO ENSURE THE OUALITY AND
INTEGRITY OF AUDIT MODIFICATIONS AND TAXPAYER BILLINGS
The Audit Section of the Motor Vehicle Division ( MVD) does n o t have
adequate controls to ensure accurate, justifiable audit assessment
modif ications and bill ings. Technical review and documentation of
assessment modifications i s weak. A1 so, procedures for bi 11 i ng taxpayers
lack sufficient separation of duties.
Audit Section Needs To Strengthen
Controls Over Modified Assessments
Presently, control over assessment modifications made by MVD auditors i s
minimal, a1 though such decisions may involve hundreds of thousands of
dollars. Documentation of auai t assessment modifications was either weak
or not available. Also, evidence of supervisory review was not apparent.
Supervisory review and internal controls are needed t o reduce the risk of
collusion, bribery or other illegal acts.
Audit assessments are additional tax amounts owed to the State by
commercial carriers. Audit assessments can occur after an auditor
conducts an examination of a commercial c a r r i e r ' s records. In addition,
if a taxpayer disagrees with the original assessment, a modification can
be requested. ! 4odifications are changes based on new information
presented or clarifications made by the audi tee. Modified assessments can
increase or reduce a taxpayer Is 1 iabil ity. Audit section procedures call
for approval of all modifications by the auditor's immediate supervisor.
Documentation and review of modified assessments i s 1 imited - The Audit
Section has weak documentation and limited review of modifications. A
review of modified assessments* by Auditor General staff found weak
documentation for the changes made. Modifications ranged from
* A random sample of 169 carrier accounts disclosed 17 cases with
modified assessments. A1 1 assessment modifications resulted in lower
l i a b i l i t y for the carrier.
approximately $ 500 to $ 368,143, and all modifications resul ted i n
reductions of the original assessment amount. Often documentation was
l i t t l e more than a cryptic note. In one case, reasons for a reduction of
almost $ 54,000 consisted of a few words scribbled on scratch paper. In
many cases modifications were based on information that had not been
available a t the time of the original audit assessment, yet even when
records needed to document the nodifications became available, the
auditors did not obtain them. In other instances, supporting
documentation was in the auditor's possession rather than in the audit
f i l e as required by MVD procedures.
MVD audit supervisors had not reviewed most of the modifications in the
sample. Audit Section procedures require supervisory sign- of f a t the
completion of a1 1 audits. A1 though the final audit resul t s were confirmed
by the supervisor, no documentation of supervisor agreement with the
modification was available in many of the files.
Controls and documentation are needed - Controls and documentation are
needed t o reduce the risk of audit personnel abusing their responsibility
and authority. blhile MVD has agreed to implement controls, the Arizona
Department of Transportation ( ADCT) should take steps t o ensure that these
controls are appropriate and in force.
Lack of documentation presents the opportunity for auditor abuse. For
exampl e, auditors might compromi se their work by knowingly issuing an
incorrect assessment mcdification i n response to improper influence by the
taxpayer. Because audit modif icaticns often i nvol ve thousands of do1 1 ars,
the risk and opportunity for such abuses are real.
Because documentation of audit assessment changes i s limited, technical or
judgmental errors can also be made. For example, errors can be made in
applying statutes, rules and Department policies. These errors may result
in incorrect assessments, inconsistencies among auditors and unfairness to
taxpayers.
The Audit Section has indicated that i t will act t o enforce existing
pol icy t o reduce possible abuses. For example, all original and amended
audit doclrments will be retained i n the audit master f i l e . Also, any
documents relating t o an assessment will be included in the f i l e . The
audit supervisor and manager will review and approve any modified audit
assessments. In addition, the new audit manual will provide specific
procedures and guide1 i nes to help auditors determine what information will
be considered in order to modify an original assessment.
Although the Audit Section has agreed to make needed improvements, ADOT
internal audit personnel shoul d periodical ly review modification
procedures to ensure their appropriateness. Follow- up by ADOT internal
audit personnel will enable an outside source to review these controls.
A1 so, ADOT's Internal Audit Group can advise the MVD Audit Section on how
to strengthen other existing controls.
Controls Are Needed Over
I axpayer Notifications
The Audit Section should strengthen controls over billings that notify a
taxpayer of the assessment owed. Current Audit Section procedures lack
separation of duties over taxpayer notifications.
Audit Section procedures give an auditor sole responsibility to complete
and send out a billing. A1 though an audit supervisor reviews the audit
f i l e for completeness before the billing i s sent out, the f i l e i s then
given back to the auditor. The auditor has the responsibility to ensure
that the billing i s made out t o the taxpayer, along with a " letter of
audit Finding." A clerk then types the billing b u t does not necessarily
verify if the amount i s correct or accurate. No supervisor reviews the
typed billing before i t i s sent to the taxpayer, nor does anyone compare
payments with the audit assessment in the f i l e . Thus, the auditor has an
opportunity to change the bill i ng without detection.
Current Audit Section procedures lack adequate separation of duties as an
internal control. The principle of separation of duties* requires that an
individual responsible for an audit cannot simul taneously be responsible
for making the assessment and preparing the billing without a third party
sign- off or verification. An auditor who performs an audit should not
have sole responsibility for preparing and mailing the billing without a
check- off system.
With 1 imited final review and inadequate separation of duties, a potential
for auditor abuse exists. The auditor could possibly reduce the amount of
the assessment or never mail the billing due to the lack of third party
verification. The lack of separation of duties increases the chances of
employee error, theft or falsification of records.
CONCLUSION
The Motor Vehicl e Divi sion Audit Section should improve control s over
assessment modifications and taxpayer notifications. Modifications and
billings need to be checked for quality, and controls are needed t o
minimize the risk of abuses. Supervisory review of modified assessments
and taxpayer notifications needs to be strengthened.
RECCrlMEl- JDATI CNS
1. The /: VC Audit Section should require that all auditors comply with
existing standards and policies governing assessment modifications and
taxpayer notifications. All reasons supporting modified assessments
should be documented in audit files.
2. The rfVD Audit Section should require supervisory review and sign- off
of modified assessments.
X- Ihe Codification of Statements on Auditing Standards, an authoritative
guide published by the American Institute of Certified Public
~ ccountants, i ~ cudle s separation of duties as a basic internal control
requirement.
3. The MVD Audit Section should implement procedures t o ensure separation
of duties over a1 1 taxpayer notifications. The procedures shoul d
require sign- off or verification by a third party.
4. ADOT internal audit personnel should periodically review MVD Audit
Section i nternal control s over modi f icati ons and taxpayer
notifications to ensure that they are working as intended. The review
should include testing the adequacy of the controls, and suggestions
for strengthening controls if they are inadequate.
THE MOTOR VEHICLE DIVISION COULD REDUCE GROWTH IN THE FflIFIBEF! OF
UNCOLLECTIBLE ACCOUNTS
The Motor Vehicle Division ( NVD) Revenue Group has difficulty coll ecting
some accounts. MVD could minimize the growth in the number of
uncoll ecti bl e accounts through various monitoring procedures. Once
accounts become uncollectible, the cost of collection i s frequently
prohibitive.
An uncollectible account i s defined by the Revenue Group as an outstanding
liability of a commercial carrier account after all allowable in- house
collections procedures have been attempted.* The Revenue Group estimates
that the current bal ance of uncoll ecti bl e accounts exceeds $ 3 mil 1 ion.
According to Revenue Group c f f i c i a l s , a large proportion of the accounts
represent monies owed by bankrupt commercial carriers.
MVD Coul d Minimize The Growth Of
Ifncci 1 ecti bl e Accounts Throucrh Ihni tori no
The Revenue Group could implement monitori~ g procedures t o reduce the
number of uncollectible accounts in the future. A major factor in the
grorvth of these accounts i s I'jlVD1s i nabil i ty to identify troubled carriers
prior t o bankruptcy. The inability t o determine if a carrier i s in
bankruptcy court means the State cannot be considered a creditor and i s
not allowed t o collect on that l i a b i l i t y once the bankruptcy i s final.
MVD could track i n- State accounts entering bankruptcy proceedings by
monitoring a month1 y pub1 ication, the Arizona Court Reporter, which
detail s Dankr~ lptcy i nfornation about Arizona based businesses. Col 1 ectors
could research the document to ascertain if any of the businesses listed
have outstanding unsecured accounts with MVD. The State would then be
able to establish itself as a creditor before bankruptcy proceedings are
final. The Arizona Department of Revenue uses this report and states i t
is very successful.
x The Revenue Group refers t o uncoll ecti bl e accounts as " unsecured
l i a b i l i t i e s . "
MVD could also improve i t s a b i l i t y t o identify out- of- State accounts that
may go bankrupt. The state of Washington monitors the financial reporting
of all carriers in and out of the state. I f a carrier's tax reports are
more than 60 days late or the carrier does not submit proper payment, the
carrier will be contacted to determine i t s financial status. If problems
continue, the state monitors the account closely to ascertain if
bankruptcy i s pending. If bankruptcy appears likely the agency will
request the Attorney General to f i l e a lien against the carrier so the
state will be able to receive all or a portion of the monies due.
The Revenue Group could also use an outside collection agency to track
bankrupt out- of- State carriers. This agency could track outstanding
accounts nationwide. The state of Oregon uses an outside collection
agency for this purpose and has found i t t o be successful.
Control of uncollectible accounts will also be improved by the
implementation of an automated tracking system. This system will enable
the Revenue Group t o better track and identify outstanding billings before
they become uncoll ectibl e. Presently, MVD i s unable to monitor carrier
accounts on a daily basis. Such monitoring will be possible with the Tax
and Revenue Group Automated Tracking System ( TARGATS) currently being
devel oped.
I4VD Has Difficulty Collecting
Monev Or~ ed For Certain Accounts
The Revenue Group has di fficul ty col 1 ecting uncol 1 ectibl e accounts because
some account balances are too small for collection by the Attorney
General.* HVD can request the Attorney General's Office t o collect on
these accounts, b u t because HVD i s charged an administrative fee and a
percentage of the amount collected, collection by the Attorney General ' s
office i s not cost effective for most accounts. Even some accounts with
larger balances may not be cost effective for collection by the Attorney
General ' s Office. Unsecured accounts with balances of $ 100 or more are
* The Revenue Group can submit accounts with balances of $ 100 or more t o
the Attorney General ' s Office for coll ection. This procedure i s used
a f t e r a l l in- house Revenue Group collection attempts are exhausted.
reviewed by the Attorney General's Office t o determine the likelihood of
collection. After review, if the Attorney General ' s Office decides the
account may not be cost effective t o collect or the carrier i s bankrupt,
the account is not pursued.
The Revenue Group i s considering using a private collection agency to
ensure payment of uncollectible accounts. The state of Oregon has had
success in using an independent agency to coll ect out- of- state accounts.
While the agency would receive a percentage of the amount i t collects as
i t s fee, the State would be receiving a t least some remuneration.
CONCLUSION
The Revenue Group has difficulty collecting accounts identified as
uncollectible. MVD could reduce the growth of these accounts through
several different monitoring procedures. Col 1 ectors coul d use an outside
agency t o ensure payment of uncoll ecti bl e accounts.
RECOMMENDATIONS
1. MVD Revenue Group should attempt to identify uncol lectibl e accounts as
early as possible. This could be achieved through:
a. consistent monitoring of the commercial carriers' financial
condition;
b. using the Arizona Court Reporter t o identify bankrupt carriers,
so the State can establish itself as a creditor in arder to
receive any l i a b i l i t i e s due; and
c. employing an outside collection agency to track and collect
accounts nationwide after a1 1 standard col lection procedures are
exhausted.
OTHER PERTINENT INFORMATION
During the audit we developed pertinent information in the following two
areas: 1 ) the Motor Vehicle Division's ( F4VD) collection of outstanding
1 iabil i t i e s , and 2 ) the abatement of uncol lectable 1 iabili ties due the ! 4VD.
MVD collections unit has increased collection of past due accounts
Due to improved coll ection procedures, MVD revenue coll ection has
increased. FlVD collectors are responsible for tracking and collecting
delinquent amounts due MVD. This includes money from audit assessments,
dishonored checks, and all other outstanding 1 iabil i ties. If a 1 iabil i ty
remains unpaid after a certain period of t i ~ e , collectors have legal
alternatives available t o assist them in collecting the delinquent amount.
The amount of revenue collected has almost doubled since fiscal year
1983- 84. The unit collected over $ 4.9 million in 1984- 85, up from
approximately $ 2.7 million in 1383- 84. As of February 1986 the unit has
already collected over $ 5 mill ion for the 1985- 86 fiscal year.
Auditor General staff found overall coll ector productivity to be crest1 y
improved. We reviewed a sample of delinquent accounts and determined that
either the accounts had been closed, or of those accounts assigned to a
collector some type of payment was currently being received. Improved
productivity is due in part to standards* developed in the Productivity
Resource Flanagement System ( PRMS) Group report. In 1983 the PRPlS Group
determined that certain standards were needed for the unit t o become more
productive. From that PRFiS study, present coll ection practices evolved.
* Standards included better tracking of aged accounts and development of
productivity measures for a1 1 col 1 ection personnel . Personnel are
tracked by the number of accounts closed, the length of time taken t o
close an account and the percentage of the amount owed that was
collected on an account.
Abatement Of Uncoll ectabl e Accounts
Presently, uncoll ectabl e revenue from closed comnercial carrier accounts
and unsecured l i a b i l i t i e s owed to MVD cannot be written off. This i s
because MVD has no specific statutory abatement policy. However, Arizona
constitutional law questions may have to be addressed before such
abatement can occur.
As noted in Finding IV ( see pages 9 through 33) a number of account
balances exist that are uncoll ectabl e for several reasons : Many accounts
have small balances; i t may not cost effective to pursue collection; and
the carrier i s bankrupt or has filed for bankruptcy protection.
Since many of the accounts are uncollectable the Revenue Group is
considering seeking legislation t o give i t clear authority t o abate those
accounts. A1 though A. R. S. $ 41 - 1 92. B. 4 gives authority to any state agency
and the Attorney General's Office to " compromise or settle" a claim owed
the State, this authority may not apply t o trust fund monies. According
to a Tax Division Attorney General representative, because the l i a b i l i t i e s
are specifically earmarked for the highway trust fund and not the general
fund, there i s a question as t o whether ADOT can write off the l i a b i l i t i e s
without specific 1 egislation. Such 1 egislation would be similar to a
statute which allows the Department of Revenue ( D O R ) to write off an
account as a bad debt if the cost t o collect the account exceeds the
amount outstanding.
AREAS FOR FURTHER AUDIT WORK
During the course o f our a u d i t we i d e n t i f i e d two p o t e n t i a l issues t h a t we
could not pursue due t o time constraints.
Are s t a t u t o r y changes needed i n procedures f o r paying taxes on
commercial fuel ~ urchases?
TIie Motor Vehicle Division ( PIVD) has d i f f i c u l ty determining whether
c e r t a i n fuel taxes have been paid. Motor c a r r i e r s may pay taxes a t the
time o f purchase and claim a c r e d i t f o r any overpayment, or they may pay
the tax along with other taxes a t the close o f t h e i r normal r e p o r t i n g
period. When the d e f e r r a l procedure was o r i g i n a l l y establ i shed, c a r r i e r s
had t o obtain MVD approval t o d e f e r t h e taxes. However, the growth i n the
number of c a r r i e r s and vendors made it d i f f i c u l t f o r MVD t o enforce the
d e f e r r a l agreement. Since November 1981 vendors have been allowed t o s e l l
fuel to any c a r r i e r and rEed only note on the invoice whether the tax was
paid or not. However, t h i s does not always occur. The documentation
needed t o monitor the d i f f e r i n g paymerlt procedures i s sometimes lacking.
MVD records i n d i c a t e t h a t some c a r r i e r s pay no tax a t the pump but
actual ly c l aim c r e d i t f o r paying those taxes. These comrnercial c a r r i e r s
may be receiving erroneous t a x c r e d i t s . Further a u d i t work i s needed t o
determine how much revenue i s being l o s t by the State because o f erroneous
c r e d i t s , and t o evaluate the impact and effectiveness o f a l t e r n a t i v e s f o r
col 1 ec ti ng the taxes.
Does MVD adequately track commercial c a r r i e r bonding l e v e l s ?
MVD requires a l l commercial c a r r i e r s to maintain a f i n a n c i a l bond. Trre
bond i s used as insurance against tax l i a b i l i t i e s incurred by the c a r r i e r ,
and provides MVD w i t h some type of payment i n case o f c a r r i e r insolvency
or bankruptcy. However, we found t h a t some bonds are i n s u f f i c i e n t t o
cover p o t e n t i a l 1 i a b i l i t i e s . According t o an I s i V D col l e c t i o r i s o f f i c i a l , of
3,000 bond claims made from A p r i l 1985 through March 1986, 35 percent o f
the c a r r i e r s examined biere undersecured. For example, one c a r r i e r haa d
bond o f only $ 12,000 when it should have been $ 55,000. Moreover, a Revenue
Group official stated that MVD does riot systematically review bonds to
ensure their adequacy. Further audit work is needed to determine the
extent to which MVD tracks commercial carrier bonding levels.
a BRUCE BABBITT
Governor August 14, 1986
CHARLES L MILLER
D, rec: or
Douglas R. Norton
Auditor General
Office of the Auditor General
2700 Korth Central Avenue
Suite 700
Phoenix, Arizona 85004
Dear Plr. Norton:
hy staff and I have reviewed the greliminary Auditor General's
Performance Audit of the Arizona Department of Transportation,
Plotor behicle Division, Revenue Croup. Because of the ongoing
changes within the Revenue Group and the general upgrading of the
P1iotor behicle Divison's revenue collection systems, the Auditor
General's Performance Audit of the Revenue Group has concentrated
on the Revenue Group Audit Section.
After careful review, I am in basic agreement with the findings
and recommendations of the Performance ~ udit Report. Only in
minor areas dealing with inferred supportive data associated with
certain findings do we disagree. These areas are included with
the attached detailed discussion.
The majority of the recommendations are consistent with currently
ongoing management programs to enhance the revenue collection,
accounting and distribution systems within the Fotor Vehicle
Division. A major enhancement program that will have a
tremendous inpact on th- audit function is the Tax and Revenue
Croup Automated Tracking System ( TARGATS) program. TARGATS will
provide for better tracking of carrier mileage, tax assessment
based on that mileage, random selection of accounts to be
audited, and computerized programs to facilitate the actuai
auai t .
The Department has assigned two auait positions to the TAKGATS
pro2ect during the uesiyn ana development stdqes of approximately
three years. The resulting revenue benefit to the state in
enhanced revenue collections are projected at three million
dollars per year. The prolected increased revenue collections
were the basis of the decision to use audit expertise. The
HIGHWAYS AERONAUTICS MOTOR VEHICLE PUBLIC TRANSIT ADMlNlSTRArlVE SERVICES TRANSPORTATION PLANNING a
PAGE 2
Department w i l l r e p l a c e t h e a u d i t o r s a s s i g n e d t o t h e p r o j e c t f o r
t h e d u r a t i o n of t h e p r o j e c t .
I am i n g e n e r a i agreement w i t h F i n d i n g # 3 , " The Motor V e h i c l e
D i v i s i o n Revenue Group Could G e n e r a t e A d d i t i o n a l Revenue By
I n c r e a s i n g t h e P r o d u c t i v i t y of Its A u d i t S e c t i o n . " he a r e i n
agreement t h a t t h e a u d i t s t a f f n o t be u t i l i z e d on s p e c i a l
p r o j e c t s n o t r e l a t e d t o t h e c o l l e c t i o n , a c c o u n t i n g or
d i s t r i b u t i o n of Highway User Revenue Funds. S t e p s a r e being
t a k e n t o a s s u r e t h a t 80%- 90% of t h e a u d i t s t a f f is u t i l i z e d
a u d i t i n g revenue y i e l d i n g a c c o u n t s . However, Department of
ran sport at ion management h a s d e t e r m i n e d t h a t t h e a u d i t s e c t i o n
w i l l conduct non- revenue y i e l d i n g a u d i t s such a s r e s t r i c t e d
d i s t r i b u t o r a c c o u n t s . These a u d i t s a r e a b s o l u t e l y n e c e s s a r y t o
i n s u r e t h a t g a s o l i n e t a x r e v e n u e s a r e p r o p e r l y r e p o r t e d and
d i s t r i b u t e d t o t h e r e s p e c t i v e a c c o u n t s o f t h e s t a t e , c o u n t i e s and
c i t i e s . I t is e s t i m a t e d t h a t a p p r o x i m a t e l y 10% of t h e c u r r e n t
a u d i t s t a f f is r e q u i r e d t o a d d r e s s t h i s a u d i t r e s p o n s i b i l i t y . In
a d d i t i o n , t h e r e a r e many o t h e r r e l a t e d f u n c t i o n s t h a t r e q u i r e
a u d i t 5 x p e r t i s e a t t e n t i o n t o i n s u r e t h e i n t e g r i t y of t h e
D e p a r t m e n t ' s t r u s t e e s h i p of t h e Highway User Revenue Funds.
Attached f o r your r e v i e w a r e s p e c i f i c comments r e l a t i v e t o each
of t h e f i n d i n g s and recommendations p r e s e n t e d i n t h e Performance
Aucl t Kepor t . I want t o thank you and your s t a f f f o r t h e
c o o p e r a t i o n , a s s i s t a n c e and c o n s i d e r a t i o n g i v e n t o our
o b s e r v a t i o n s and comments d u r i n g t h e a u d i t 2 r o c e s s .
i CI- iARLES L. MILLER
D i r e c t o r
Department o f T r a n s p o r t a t i o n
FINDING I
Additional Audit Staff Could Generate Millions of Dollars
i n Revenue for the Highway User Revenue Fund
The Department of Transportation agrees with the proposition that
more auditors w i l l generate more assessments for the Eighway User
Revenue Fund. The Department however, does not agree with the
supporting s t a t i s t i c a l data that would indicate a low audit
coverage implied by Table 2 and Table 3 of t h e r e p o r t , since the
organization of audit sections vary from s t a t e t o s t a t e and the
data was never verified.
The Department agrees with the recommendations and has requested
and been appropriated additional a u d i t p o s i t i o n s . The Motor
VeElicle Eivision has included requests for additional auditors in
the Division's five year operating budget plan. The basis for
the past and current requests is t o allow the audit function t o
grow consistently with the growth i n t o t a l HURF revenues. The
additional amount of assessments the additional auditors w i l l
generate w i l l almost certainly exceed, by significant margin, the
additional a u d i t c o s t s . A more exact estimate of revenue yield
from additional auditors is not possible t o predict and such a
forecast is highly speculative. ?\% ether additional s t a f f w i l l
yield revenues at the same recovery r a t e as existing s t a f f is not
possible t o predict.
FINDING 11
Current Audit Selection Procedures Are Rot Effective
The Department agrees with t h i s finding, however, not with the
supporting data. The report presents instances of underreporting
by small accounts implying that t h i s may be a population trend.
Yet, the report i t s e l f s t a t e s , "... complete data is not
available, ..." If corplete data i s not available inferences
should not be made.
The Department agrees with the intent of the recommendations that
an improved a u d i t selection process i s needed. A s mentioned in
the report, the Revenue Group w i l l improve i t s audit selection
process through the Tax and Revenue Croup Automated Tracking
System ( TARGATS). I n the interim, the Pudit Section is
developing manual selection c r i t e r i a that w i l l p a r a l l e l the
TARGATS process.
PAGP 3
FIMDING I11
The Motor Vehicle Division Revenue Group Could Generate
Additional Revenue By Increasing the Productivity of
Its Audit Section
The Departpent agrees with this finding but with reservation. It
is the opinion of the Department that the function of the MVD
Audit Section include, necessary but limited, activities not
related to direct tax audit assessments.
The Department agrees that audit staff productivity can be
increased through the use of personal computers and has included
a budget issue for FY 87/ 88 requesting them.
FIMDING IV
The Audit Section Lacks Adequate Controls to Ensure The
Quality & Integrity of Audit Modifications & Taxpayer Billings
The Department of Transportation agrees with this finding. The ( I
recommendations are being implemented to insure existing
standards and policies governing assessment notification and
taxpayer notifications are complied with. The Audit Section will
require supervisory review and sign- off of all modified
assessments.
( I
FIWDING V
The Plotor Vehicle Division Could Reduce Growth
In The Number of Uncollectable Accounts
The Department agrees with this finding. The Department agrees
with the recormendations and has established close coordination
with Arizona Attcrney General's Office to identify bankrupt motor
carriers so as to establish the State as a creditor. The Motor
Vehicle Civision will investigate the legality and effectiveness
of an outside collection agency to track and collect accounts
nationwide. ( I